United States of America v. Josh Lane

The opinion of the court was delivered by: Edward J. Garcia United States District Judge

BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Suite 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for JOSH LANE

STIPULATION & ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER SPEEDY TRIAL ACT

IT IS HEREBY STIPULATED AND AGREED between the defendant, Josh Lane, by and through his defense counsel, Bruce Locke, and the United States of America by and through its counsel, Assistant U.S. Attorney Heiko Coppola, that the status conference presently set for March 25, 2011 at 10:00 a.m., should be continued to April 8, 2011 at 10:00 a.m., and that time under the Speedy Trial Act should be excluded from March 25, 2011 through April 8, 2011.

The reason for the continuance is that the parties are working out the last details of the plea agreement and that process requires the parties and the government agents to review some of the memoranda of interviews and discovery. Additionally, once the necessary changes are made, defense counsel will need additional time to review the plea agreement with the defendant in order to be fully prepared for the anticipated guilty plea on April 8, 2011.Accordingly, the time between March 25, 2011 and April 8, 2011 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation.The parties stipulate that the ends 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). Mr. Coppola has authorized Mr. Locke to sign this pleading for him.

DATED: March 22, 2011

BRUCE LOCKE Attorney for Josh Lane

DATED: March 22, 2011

For HEIKO COPPOLA Attorney for the United States

IT IS SO ORDERED.

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