IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
December 4, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
NIESHA JACKSON DEFENDANT.
The opinion of the court was delivered by: Hon. Frank C. Damrell, Jr. U.S. District Judge
STIPULATION AND ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from November 30, 2009 to January 25, 2010 at 10:00 a.m.. They stipulate that the time between November 30, 2009 and January 25, 2010 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). Specifically, the United States has disclosed voluminous discovery, including documents and audio recordings, and counsel needs time for review of those materials. Additionally, counsel for the defendant reports technical problems reviewing electronic files disclosed in discovery. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
Respectfully Submitted, LAWRENCE G. BROWN United States Attorney DATE: December 4, 2009 MATTHEW D. SEGAL Assistant U.S. Attorney
DATE: December 4, 2009 SUZANNE LUBAN Attorney for Defendant
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