The opinion of the court was delivered by: Judge: William B. Shubb
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
IT IS HEREBY STIPULATED between the parties, William Wong, Assistant United States Attorney, and Douglas J. Beevers, Assistant Federal Defender, attorney for defendant JASON RAUL SANTIAGO, that the status conference of July 19, 2010 at 8:30 a.m., be vacated, and the matter be set for status conference on August 2, 2010 at 8:30 a.m.
The reason for the continuance is to allow the parties additional time to negotiate a resolution. In addition, defense counsel is in trial in United States v. Sue Vue, CR-S-09-362, beginning the week of July 19, 2010. The trial is expected to last four days. The parties agree a continuance is necessary for this purpose, and agree to exclude time under the Speedy Trial Act accordingly.
IT IS STIPULATED that the period from the date of the parties' stipulation, July 14, 2010, and up to and including August 2, 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: July 14, 2010 Respectfully submitted, DANIEL J. BRODERICK Federal Defender DOUGLAS J. BEEVERS Assistant Federal Defender Attorney for Defendant JASON RAUL SANTIAGO
Dated: July 14, 2010 BENJAMIN B. WAGNER United States Attorney WILLIAM WONG Assistant U.S. Attorney
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for July 19, 2010, be continued to August 2, 2010 at 8:30 a.m. Based on the representation of defense counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case would deny defendant reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the August 2, 2010 status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4, to allow defense counsel time to prepare.
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