The opinion of the court was delivered by: Judge: Hon. William B. Shubb
DANIEL J. BRODERICK, Bar# 89424 Federal Defender BENJAMIN D. GALLOWAY, Bar# 214897 Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone (916) 498-5700 Attorney for Defendant PAUL LARRY MACK
STIPULATION AND [PROPOSED]
It is hereby stipulated and agreed to between the United States of America through JASON HITT, Assistant U.S. Attorney, and defendant, PAUL MACK, by and through his counsel, BENJAMIN GALLOWAY, Assistant Federal Defender, ALEXANDER HUGHES by and through his counsel, A. STANLEY KUBOCHI, ERIK SOLISFOX, by and through his counsel CHRISTOPHER HAYDN-MYER and LAVERNE FIELDS, by and though her counsel STEVEN D. BAUER that the status conference set for Monday, December 12, 2011, be continued to Monday, January 23, 2012 at 9:30 a.m..
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendants, to examine possible defenses and to continue investigating the facts of the case.
In addition, several of the parties are in active plea negotiations and are working toward the negotiated resolution of their cases. Additional time is needed for that purpose.
Speedy trial time is to be excluded from the date of this order through the date of the status conference set for January 23, 2012, pursuant to 18 U.S.C. § 3161 (h)(8)(B)(iv) [reasonable time to prepare] (Local Code T4).
The above stipulation of the parties is accepted. The status conference set for December 12, 2011, is VACATED. This case is ordered to be re-calendared on January 23, 2012 at 9:30 a.m., for status conference.
The court finds, based on the reasons stated above, that the interests of justice served by granting this continuance outweigh the interests of the defendant and the public in a speedy trial.
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