DANIEL J. BRODERICK, Bar #89424 Federal Defender Lexi Negin, Bar #250376 Assistant Federal Defender 801 I Street, 3rd. Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant STEPHEN CRAIG SAEGER
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS HEARING AND TO
EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
Date: May 14, 2012
Time: 9:30 a.m.
Judge: William B. Shubb
It is hereby stipulated and agreed to between the United States of America through JASON HITT, Assistant U.S. Attorney, and defendant, STEPHEN CRAIG SAEGER, by and through his counsel, LEXI NEGIN, Assistant Federal Defender, that the status conference set for Monday, March 19, 2012, be continued to Monday, May 14, 2012, at 9:30 a.m.
The reason for this continuance is to allow defense counsel additional time to continue examining the possible defenses and investigating the facts of the case, and for further meetings between the parties with the goal being to resolve the case by way of a disposition.
It is further stipulated that the time period from the date of this stipulation, March 13, 2012, through and including the date of the new status conference hearing, May 14, 2012, shall be excluded under the Speedy Trial Act (18 U.S.C. §3161(h)(7)(A) &(B)(iv) and Local Code T4, due to the need to provide defense counsel with the reasonable time to prepare, and that the ends of justice to be served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial.
Based on the reasons set forth in the stipulation of the parties filed on March 13, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDERED that the status conference currently scheduled for Monday, March 19, 2012, be vacated and that the case be set for Monday, May 14, 2012, at 9:30 a.m. The Court finds that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that, for the reasons stated in the parties' March 13, 2012, stipulation, the time within which the trial of this matter must be commenced under the Speedy Trial Act is excluded during the time period from the date of this stipulation, March 13, 2012, through and including May 14, 2012, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) [reasonable time to prepare] and Local Code T4.
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