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; ORDER THEREON
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 February 9, 2012 at 9:00 a.m., should be continued to March 8, 2012 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from February 9, 2012 through March 8, 2012.
The reason for the continuance is the defense needs additional time to conduct pretrial investigation , including the identification and interview of the alleged victims and witnesses, and review of recently provided discovery; complete potential plea negotiations; and prepare for trial. The exclusion of time is also necessary to ensure continuity of counsel. The case is currently set for trial on June 4, 2012. Accordingly, the time between February 9, 2012 and March 8, 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, the Status Conference in this matter is continued from February 9, 2012 to March 8, 2012 at 9:00 a.m.
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