IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
March 7, 2011
UNITED STATES OF AMERICA,
EDDIE TERRELL WILSON
The opinion of the court was delivered by: Hon. John A. Mendez U.S. District Judge
STIPULATION AND ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from March 8, 2011 to April 26, 2011 at 9:30 a.m. They stipulate that the time between March 8, 2011 and April 26, 2011, 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)and Local Code T-4. Specifically, defense counsel needs additional time to review the discovery that has been provided in this matter to date and to perform additional investigation. The parties have also reached a tentative plea agreement that needs to be formalized. Defense counsel will need additional time to review the terms of the plea agreement with the defendant in order to prepare for the change of plea hearing. 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).
Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney
DATE: March 7, 2011 By: /s/ Heiko P. Coppola
HEIKO P. COPPOLA Assistant U.S. Attorney
DATE: March 7, 2011
MARK REICHEL Attorney for Defendant
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