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 NON-EVIDENTIARY HEARING DATE, AND CONTINUING BRIEFING SCHEDULE 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. Based on the government's opposition brief, it has become necessary for the defense to inspect the physical evidence seized and booked in this case. The parties are currently coordinating an evidence viewing for that purpose. As such the requested continuance 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: Completed Defendant's Optional Reply: March 12, 2012 Non-evidentiary Hearing and Evidentiary Hearing Setting: March 26, 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 26, 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).
© 1992-2012 VersusLaw ...