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] ORDER
Date: February 13, 2012 Time: 9:30 a.m.
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, that the status conference set for Monday, January 23, 2012, be vacated and reset for a change of plea hearing on Monday, February 13, 2012 at 9:30 a.m..
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case. In addition, the parties have reached a tentative resolution of this case and a related state case and need additional time to finalize the plea agreement.
Speedy trial time is to be excluded from the date of this order through the date of the change of plea hearing set for February 13, 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 as to defendant Paul Larry Mack set for January 23, 2012, is VACATED. This case is ordered to be re-calendared on February 13, 2012 at 9:30 a.m., for a change of plea.
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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