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United States v. Ross

May 19, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
JOHNNIE EARL ROSS, DEFENDANT.



The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

Date: June 25, 2010

Time: 9:00 a.m.

Judge: Garland E. Burrell, Jr.

It is hereby stipulated between the parties, Todd Leras, Assistant United States Attorney, attorney for plaintiff, and Douglas Beevers, Assistant Federal Defender, attorney for defendant JOHNNIE EARL ROSS, that the Status Conference hearing date of May 21, 2010, be vacated and a new Status Conference hearing date of June 25, 2010 at 9:00 a.m. be set.

This continuance is requested because the parties are still negotiating a plea agreement. Additional time is needed by United States Probation Officer, Lori V. Clanton to prepare the pre-plea presentence report. The parties agree a continuance is necessary for these purposes, and agree to exclude time under the Speedy Trial Act accordingly.

IT IS STIPULATED that the period from the date of the parties' stipulation, May 19, 2010, and up to and including June 25, 2010, shall be excluded in computing the time within which trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C §3161(h)(7)(A) and (B) (ii) and (iv) and Local Code T4 (ongoing preparation of defense counsel).

Dated: May 19, 2010

Respectfully submitted,

DANIEL J. BRODERICK Federal Defender /s/ Douglas J. Beevers

DOUGLAS J. BEEVERS Assistant Federal Defender Attorney for Defendant JOHNNIE EARL ROSS

Dated: May 19, 2010

BENJAMIN B. WAGNER United States Attorney

TODD LERAS Assistant U.S. ...


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