STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the judgment and sentencing currently set for January 25, 2010 at 8:30 a.m., be continued to March 29, 2010 at 8:30, and stipulate that the time beginning January 25, 2010, and extending through March 29, 2010, should be excluded from the calculation of time under the Speedy Trial Act. 18 U.S.C. § 3161.
The defendant has pleaded guilty in this case and is awaiting sentencing. The defendant may be a witness in, or needed to provide assistance related to, the government's case in United States v. Blanford. That trial is currently set to begin on February 17, 2010. Additional time is needed by the parties to prepare sentencing memoranda in this matter.
The parties believe that the continuance should be excluded from the calculation of time under the Speedy Trial Act. The additional time is necessary to ensure effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4. 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).
LAWRENCE G. BROWN United States Attorney
LAUREL LOOMIS RIMON Assistant U.S. Attorney
JOHN M. RUNFOLA Attorney for the Defendant
The Sentencing in case number S-07-386 WBS, currently set for Monday, January 25, 2010, at 8:30 a.m., is continued to Monday, March 29, 2010, at 8:30 a.m., and the time beginning January 25, 2010, and extending through March 29, 2010, is excluded from the calculation of time under the Speedy Trial Act in accordance with 18 U.S.C. § 3161 and Local Code T4.
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