The opinion of the court was delivered by: Judge: Honorable Garland E. Burrell, Jr.
STIPULATION AND [PROPOSED ORDER] CONTINUING
Date: August 12, 2011
Time: 9:00 a.m.
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michael M. Beckwith, Assistant United States Attorney, together with counsel for defendant Patricia Albright, Timothy Zindel, Esq., and counsel for defendant Jordan Wirtz, John R. Manning, Esq., that the status conference presently set for July 22, 2011 be continued to August 12, 2011, at 9:00 a.m., thus vacating the presently set status conference.
Further, all of the parties, the United States of America and all of the defendants as stated above, hereby agree and stipulate that the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendants in a speedy trial and that time under the Speedy Trial Act should therefore be excluded under Title 18, United States Code Section 3161(h)(7)(A) and (B)(ii) and (iv) and Local Code T-4 (to allow defense counsel time to prepare) from the date of the parties stipulation, July 19, 2011, to and including August 12, 2011.
The defense requests more time to review the discovery and conduct investigation.
Dated: July 19, 2011 /s/ Timothy Zindel TIMOTHY ZINDEL Attorney for Defendant Patricia Albright Dated: July 19, 2011 /s/ John R. Manning JOHN R. MANNING Attorney for Defendant Jordan Wirtz Dated: July 19, 2011 Benjamin B. Wagner United States Attorney by: /s/ Michael M. Beckwith MICHAEL M. BECKWITH Assistant U.S. Attorney JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 Attorney for Defendant JORDAN WIRTZ
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. ) PATRICIA ALBRIGHT, and, ) JORDAN WIRTZ, Defendants.
GOOD CAUSE APPEARING, it is hereby ordered that the July 22, 2011 status conference be continued to August 12, 2011 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT
IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(ii) and (iv) and Local Code T4 (preparation by defense counsel).
© 1992-2011 VersusLaw ...