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United States of America v. Shead

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


November 3, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
SHEAD, ET. AL.
DEFENDANTS.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME CONTINUING STATUS CONFERENCE AND RODNEY

DATE: November 4, 2011 TIME: 9:00 a.m.

COURT: Hon. Garland E. Burrell, Jr.

Stipulation The parties, through undersigned counsel, stipulate that the status conference for defendant Rodney Shead, scheduled for November 4, 2011, may be continued to December 2, 2011, at 9:00 a.m. The parties are attempting to resolve the case and need additional time to research and exchange information regarding the applicable sentencing guidelines and other matters relating to the factual basis for the proposed plea agreement. 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. The parties also agree that time may be excluded from the speedy trial calculation under the Speedy Trial Act for counsel preparation, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4.

The Government has authorized the defense counsel for Rodney Shead to sign this stipulation on his behalf.

DATED: November 2, 2011 BENJAMIN B. WAGNER United States Attorney by /s/ Scott N. Cameron, for Todd Leras Assistant U.S. Attorney DATED: November 2, 2011 by /s/ Scott N. Cameron Scott N. Cameron Attorney for RODNEY SHEAD

Good cause appearing,

The status conference, scheduled for November 4, 2011, is continued to December 2, 2011, at 9:00 a.m.

Time is excluded from the speedy trial calculation pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 for counsel preparation.

20111103

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