MICHAEL B. BIGELOW Attorney at Law - SBN 65211 331 J Street, Suite 200 Sacramento, California 95814 Telephone: (916) 443-0217 Email: LawOffice.firstname.lastname@example.org Attorney for Defendant Jaime Marotte
STIPULATION CONTINUING STATUS CONFERANCE (PROPOSED) ORDER
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, together with counsel for defendant JAIME MAROTTE in the above referenced matter that the status conference presently set for February 6, 2012 be continued to March 19, 2012, at 9:30 a.m., for a change of plea, thus vacating the presently set status conference.
Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code§ 3161(h)(8)(B)(iv) (continuity of counsel/reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of new the new date for change of plea, March 19, 2012.
This continuance is requested because the parties continue to negotiate resolution which has been agreed upon in principal and because of scheduling issues encountered by undersigned counsel for defendant Marotte.
Respectfully submitted, BENJAMINE B. WAGNER UNITED STATES ATTORNEY DATED: January 30, 2012 /s/ JASON HITT Jason Hitt Assistant United States Attorney DATED: January 30, 2012 /s/ MICHAEL B. BIGELOW Michael B. Bigelow Attorney for Jaime Marotte
IT IS ORDERED THAT: Pursuant to stipulation by all parties the Status Conference in the above referenced matter, presently set for February 6, 2012 is rescheduled for March 19, 2012 for a change of plea at 9:30 AM. It is also agreed by the parties that time should be excluded for continuity of counsel and reasonable time for effective preparation and complexity within the meaning of the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), and Local Codes T2 and T4, from the date of the filing of the order until the date of new the status conference, March 19, 2012.
The Court specifically finds that the ends of justice are served by granting the requested continuance and outweigh the best interest in the public and the defendants in a speedy trial.
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