IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 25, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
RICHARD NUWINTORE DEFENDANT.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties are continuing to address issues concerning the weight and admissibility of the evidence in this case. Thus, they request a further continuance of the status conference.
The parties request that the status conference in this case be continued to March 29, 2010 at 8:30 a.m.. They stipulate that the time between March 1, 2010 and March 29, 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 parties are evaluating the evidence (written and electronic), its weight, and its admissibility. 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).
Pursuant to Rule 12(c), the parties stipulate and agree that any pretrial motions will be filed by March 29, 2010.
DATE: February 25, 2010
MATTHEW D. SEGAL Assistant U.S. Attorney
MALCOLM SEGAL Attorney for Defendant
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