The opinion of the court was delivered by: Judge Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE
It is hereby stipulated between the parties, Todd Leras, Assistant United States Attorney, attorney for plaintiff, and Douglas J. Beevers, Assistant Federal Defender, attorney for defendant JOHNNIE EARL ROSS, that the Status Conference hearing date of January 29, 2010, be vacated and a new Status Conference hearing date of Friday, March 12, 2010, at 9:00 a.m., be set.
This continuance is requested because the parties are still negotiating a plea agreement and additional time is needed. The parties are hoping to avoid the possibility of having a sentence reopened if retroactive changes are made to the crack guidelines. In addition, defense counsel will need more time to communicate with Mr. Ross as he is being held in Butte County Jail.
IT IS FURTHER STIPULATED and agreed that the period from January 29, 2010, through and including March 12, 2010, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to Title 18, U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 for continuity and preparation of counsel.
DANIEL J. BRODERICK Federal Defender
DOUGLAS J. BEEVERS Assistant Federal Defender Attorney for Defendant JOHNNIE EARL ROSS
BENJAMIN B. WAGNER United States Attorney TODD LERAS Assistant U.S. Attorney per telephonic authorization
GARLAND E. BURRELL, JR. United States ...