STIPULATION AND ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME
The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Michael M. Beckwith, Assistant United States Attorney, and defendants, Patricia Jane Albright, through her attorney of record, Zenia Gilg, and Jordan Robert Wirtz, through his attorney of record Carrie Kostiner, hereby stipulate and agree that the status conference set for June 28, 2011, be continued to July 26, 2011, at 9:15 a.m.
The parties submit that the ends of justice are served by the Court excluding time, so that counsel for each 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); Local Code T4. Therefore, the parties have agreed and respectfully request that the Court set the date of July 26, 2011, at 9:15 a.m., for the status conference.
Accordingly, the parties stipulate that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(F) and Local Code T4, to give the defendants time to further review the discovery and to adequately prepare.
BENJAMIN B. WAGNER United States Attorney Dated: June 22, 2011 By: MICHAEL M. BECKWITH Assistant U.S. Attorney Attorney for Plaintiff DATED: June 22, 2011 By: ZENIA GILG Attorney for Defendant PATRICIA JANE ALBRIGHT DATED: June 22, 2011 By: CARRIE KOSTINER Attorney for Defendant JORDAN ROBERT WIRTZ
For the reasons stated above, the status conference in case number CR. S-2:11-0226 LKK, currently set for June 28, 2011, is continued to July 26, 2011; and the time beginning June 28, 2011, and extending through July 26, 2011, is excluded from the calculation of time under the Speedy Trial Act for effective defense preparation. The Court finds that interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(7)and Local Code T4.
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