SCOTT N. CAMERON Attorney at Law 1007 7th Street, Suite 319 Sacramento, California 95814 Telephone: (916) 442-5230 Attorney for: CY IRVING BROWN
STIPULATION AND [PROPOSED] ORDER
CONTINUING BRIEFING SCHEDULE AND
NON-EVIDENTIARY HEARING DATE, AND EXCLUDING TIME
The parties, through undersigned counsel, stipulate that the briefing schedule and non-evidentiary hearing may be continued pursuant to the below listed schedule. Counsel for the defendant is scheduled to be in an unrelated jury trial on the date currently set for the non-evidentiary hearing in this matter. Moreover, the number of issues raised in defendant's moving papers exceeds what was initially contemplated when the original briefing schedule was agreed to by the parties. Both parties are conducting additional investigation and legal research and the additional time requested is necessary for counsel preparation.
Therefore, the parties stipulate that the briefing schedule and non-evidentiary hearing date may be rescheduled as follows:
Defendant's Moving Papers: Completed Government's Opposition: February 13, 2012 Defendant's Optional Reply: February 27, 2012 Non-evidentiary Hearing and Evidentiary Hearing Setting: March 12, 2012, at 9:30 a.m.
IT IS FURTHER STIPULATED THAT time for trial under the Speedy Trial Act be excluded pursuant to 18 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.
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.
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 March 12, 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).
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