The opinion of the court was delivered by: Judge: Hon. Garland E. Burrell
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
Date: August 12, 2011 Time: 9:00 a.m.
IT IS HEREBY STIPULATED between the parties, SAMUEL WONG, Assistant United States Attorney for plaintiff United States of America, on the one hand, and DOUGLAS BEEVERS, Assistant Federal Defender, attorney for defendant JAYMAR DWAUNE JAMERSON, on the other hand, that the status conference of July 29, 2011 at 9:00 a.m., be vacated, and the matter be set for status conference on August 12, 2011, at 9:00 a.m.
The reason for the continuance to allow defense counsel additional time to review and investigate the facts of the case. The parties agree a continuance is necessary for these purposes, and agree to exclude time under the Speedy Trial Act accordingly.
IT IS STIPULATED that the period from the date of the parties' stipulation, July 28, 2011 and up to and including the August 12, 2011, Status Conference, shall be excluded in computing the time within which trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C §3161(h)(7)(A) and (B)(iv) and Local Code and T4 (ongoing preparation of defense counsel).
Dated: July 28, 2011 Respectfully submitted,
DANIEL BRODERICK Federal Defender /s/ Doug Beevers DOUG BEEVERS Assistant Federal Defender Attorney for Defendant JAYMAR DWAUNE JAMERSON
BENJAMIN B. WAGNER United States Attorney By: SAMUEL WONG Assistant U.S. Attorney Attorney for Plaintiff
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for July 29, 2011, be continued to August 12, 2011, at 9:00 a.m. Based on the representation of defense counsel and good cause appearing therefrom, the Court hereby finds that it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in 18 U.S.C. § 3161, the requested continuance is necessary to provide defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial.
It is ordered that time from the date of the parties' stipulation, July 28, 2011, up to and including, the August 12, 2011, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(7)(A) and (B)(iv) and Local Code T4 (allow defense counsel reasonable time to prepare).