STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the judgment and sentencing currently set for March 29, 2010 at 8:30 a.m., be continued to July 19, 2010 at 8:30, and stipulate that the time beginning March 29, 2010, and extending through July 19, 2010, should be excluded from the calculation of time under the Speedy Trial Act.
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 June 15, 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).
BENJAMIN B. WAGNER 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, March 29, 2010, at 8:30 a.m., is continued to Monday, July 19, 2010, at 8:30 a.m., and the time beginning March 29, 2010, and extending through July 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.