The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell, Jr.
DANIEL J. BRODERICK, Bar #89424 Federal Defender JEFFREY L. STANIELS, Bar #91413 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant KENNETH ALBERT WEBB
STIPULATION AND [PROPOSED] ORDER
Date: March 4, 2011 Time: 9:00 a.m.
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Carolyn Delaney, counsel for Plaintiff, and Assistant Federal Defender Jeffrey Staniels, counsel for defendant KENNETH ALBERT WEBB, as follows:
The status conference scheduled for March 4, 2011, was vacated and the matter continued until April 15, 2011, for further status conference at the request of the defense with the agreement of government counsel. A stipulation to the continuance was not filed as the result of defense counsel's inadvertent oversight.
The reason for the continuance was to allow for further consultation with Mr. Webb, and for consideration of various other aspects of defense preparation including other investigation and possible pretrial motions.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act be excluded between March 4, 2011 and April 15, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(ii), Local Code T-2 (complexity), given the frequent need in cases of this sort to engage the services of forensics computer analysts in various ways, and
(B)(iv)(time to prepare), Local Code T-4. This was the intent and agreement of the parties at the time the court's clerk was notified of the requested continuance.
GARLAND E. BURRELL, JR. United States District Judge
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