IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 4, 2012
UNITED STATES OF AMERICA,
TYNISHA HORNBUCKLE, ET AL.,
The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Suite 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for TYNISHA HORNBUCKLE
STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER SPEEDY TRIAL ACT;
IT IS HEREBY STIPULATED AND AGREED between the defendants, Tynisha Hornbuckle, Tamrell Hornbuckle, Latrelle Hornbuckle, Cherrelle Hornbuckle, and Tammy Brown, by and through their undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Kyle Reardon, that the status conference presently set for January 5, 2012 at 9:00 a.m., should be continued to February 16, 2012 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from January 5, 2012 through February 16, 2012.
The reason for the continuance is the defense needs additional time to complete potential plea negotiations and to prepare for trial. The case is currently set for trial on June 4, 2012. Accordingly, the time between January 5, 2012 and February 16, 2012 should be excluded from the Speedy Trial calculation pursuant to Title 18, States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation.The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Chastaine, Mr. Hedberg, Mr. Peters, Mr. Warriner, and Mr. Reardon have authorized Mr. Locke to sign this pleading for them. .
The Court finds, for the reasons stated above, that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial, and, therefore,
IT IS SO ORDERED.
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