IN THE UNITED STATES OF DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
July 8, 2011
UNITED STATES OF AMERICA,
JUAN DIEGO PAUCAR SCOTT EDWARD WHITNEY ERIK TROY ALEXANDER , DEFENDANTS.
DAVID D. FISCHER, SBN 224900 Attorney at Law 1007 7th Street, Suite 100 Sacramento, CA 95814 Telephone: (916) 447-8600 Fax: (916) 930-6482 E-Mail: firstname.lastname@example.org Attorney for Defendant ERIK ALEXANDER
DEFENDANT'S STIPULATION FOR CONTINUANCE OF STATUS CONFERENCE; AND ORDER STIPULATION
Plaintiff, United States of America, by and through its counsel, Samantha Spangler and defendant Erik Alexander, by and through his counsel, David D. Fischer, agree and stipulate to vacate the date set for status conference, July 11, 2011 at 10:00 a.m., in the courtroom of the Honorable Frank C. Damrell, Jr. The parties agree that the case may be set for further status conference on August 8, 2011, at 10:00 a.m. This stipulation has been reached because defense is in the process of wrapping up its investigation in this case. The defense is in the process of finishing up two out of state interviews and one intrastate interview. Travel arrangements have been made to accomplish these interviews.
The Government concurs with this request.
The parties further agree and stipulate that the time period from the filing of this stipulation until August 8, 2011, should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED.
For the reasons set forth in the accompanying stipulation of counsel, the defendant's unopposed motion to continue the case date is granted; the new date for further status conference is August 8, 2011, at 10:00 a.m. The date of July 11, 2011, 10:00 a.m. is VACATED; and the above-captioned matter is set for further status conference on August 8, 2011, at 10:00 a.m. The court finds excludable time in this matter through August 8, 2011, under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (h)(7)(B)(iv), Local Code T4.
IT IS SO ORDERED
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