IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
March 16, 2012
UNITED STATES OF AMERICA,
JOE L. REGALADO,
ZBENJAMIN B. WAGNER United States Attorney MATTHEW G. MORRIS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2700
STIPULATION AND [PROPOSED] ) ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from March 19, 2012 to May 7, 2012 at 9:30 a.m. They stipulate that the time between March 19, 2012, and May 7, 2012, should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T4. Specifically, the attorney for the defendant is recovering from an injury and will be reviewing previously-produced discovery before being able to discuss possible resolution without trial. The attorney for the government spoke with Justin on the staff of the defense attorney and confirmed the May 7, 2012 date as well as the reasons for the defense need for additional time.
The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
IT IS SO ORDERED.
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