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United States of America v. Cy Irving Brown

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


November 17, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
CY IRVING BROWN
DEFENDANT.

SCOTT N. CAMERON Attorney at Law 1007 7th Street, Suite 319 Sacramento, California 95814 Telephone: (916) 442-5230 Attorney for: CY IRVING BROWN

ORDER STIPULATION AND [PROPOSED] TO CONTINUE STATUS HEARING, SET MOTION SCHEDULE, AND EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT

Stipulation This case is currently scheduled for a status hearing on November 21, 2011. The parties, through undersigned counsel, stipulate that additional time is needed for defense preparation and for the drafting of a defense motion to suppress evidence. As such, the parties stipulate to the following briefing schedule and non-evidentiary hearing date and request that the status hearing be continued accordingly:

Defendants' Moving Papers: December 5, 2011 Government's Opposition: January 2, 2012 Defendants' Optional Reply: January 16, 2012 Non-evidentiary Hearing and Determination of Need for Evidentiary Hearing: January 30, 2012, at 9:30 a.m.

It is further stipulated that time for trial under the Speedy Trial Act be excluded pursuant to 19 U.S.C. § 3161(h)(1)(D) & (h)(7)(A) & (B)(iv), Local Codes E and T-4. The parties agree that the interests of justice served by granting this continuance outweigh the best interests of the public and defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

The prosecutor has authorized the defense counsel for Cy Brown to sign this stipulation on his behalf.

Counsel for Cy Brown Order For the reasons stated in the above stipulation of counsel, the briefing schedule and non-evidentiary hearing date stipulated to by counsel is hereby ordered and that the status hearing currently set for November 21, 2011, be continued accordingly. The court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. Time for trial under the Speedy Trial Act is excluded from the date of the execution of this stipulation through January 30, 2012, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) [reasonable time to prepare], Local Code T4, and 18 U.S.C. § 3161(h)(7)(1)(D), Local Code E (commencing with the filing of motions).

20111117

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