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The United States of America v. D. Bowser

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


February 9, 2012

THE UNITED STATES OF AMERICA, PLAINTIFFS,
v.
D. BOWSER DEFENDANT.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERENCE AND EXCLUDABLE TIME REGINALD

Reginald D. Bowser, by and through his counsel, Philip A. Schnayerson, and the United States Government, by and through its counsel, William S. Wong, Assistant United States Attorney, stipulate and respectfully request the Court to continue the status conference hearing presently set for February 10, 2012, to February 24, 2012, at 9:00 a.m. The parties further stipulate that the time period from February 10, 2012, up to and including the new status conference date of February 24, 2012, should be excluded from computation of time for commencement of trial under the Speedy Trial Act, based upon the need for defense counsel to continue discussions with the government regarding resolution of the case.

For these reasons, the defendant, defense counsel, and the government agree additional time is required for the defense to effectively evaluate the case and prepare for trial pursuant to 18 U.S.C. § 3161 (h) (8) (B) (iv), Local Code T4.

DATED: February 8, 2012 Respectfully submitted, /s/ Philip A. Schnayerson PHILIP A. SCHNAYERSON Attorney for Defendant REGINALD D. BOWSER DATED: February 8, 2012 /s/ Philip A. Schnayerson Authorized to sign for William Wong Assistant United States Attorney on 02/08/2012 (PROPOSED) ORDER

Based on the representations and stipulation of counsel, IT IS HEREBY ORDERED THAT

1. The status conference set for February 10, 2012, at 9:00 a.m. is vacated;

2. A status conference is set for February 24, 2012, at 9:00 a.m.; and

3. Based upon the representations and stipulation of the parties, the court finds that the time exclusion under the Speedy Trial Act, pursuant to Title 18 U.S.C. § 3161 (h)

(8) (B) (iv) applies and the ends of justice outweigh the best interest of the public and the defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded from February 10, 2012, up to and including February 24, 2012.

20120209

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