IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 22, 2011
UNITED STATES OF AMERICA,
The opinion of the court was delivered by: Judge: Hon. William B. Shubb
DANIEL J. BRODERICK, Bar #89424 Federal Defender DOUGLAS BEEVERS, U.S.V.I. Bar #766 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant NATANAEL FAUSTINO
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: September 19, 2011 Time: 8:30 a.m.
The parties request that the status conference in this case be continued from August 22, 2011, to September 19, 2011 at 8:30 a.m. They stipulate that the time between August 22, 2011 and September 19, 2011 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the 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). Specifically, counsel needs additional time to negotiate a resolution to this matter and to investigate the facts of the case. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(B)(iv).
Dated: August 19, 2011 Respectfully submitted,
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for August 22, 2011, be continued to September 19, 2011, at 8:30 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that 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 this Order, to and including, the September 19, 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)(B)(iv) and Local Code T-4.
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