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United States of America v. Joseph Gage

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


April 25, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JOSEPH GAGE,
DEFENDANT.

BENJAMIN B. WAGNER United States Attorney ELANA S. LANDAU Assistant U.S. Attorney 2500 Tulare St, Suite 4401 Fresno, California 93721 Telephone: (559) 497-4083

STIPULATION AND ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from April 30, 2012 to May 14, 2012 at 10:00a.m.. They stipulate that the time between April 30, 2012 and May 14, 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 and to allow for plea negotiations, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). Specifically, the parties are attempting to determine the defendant's criminal history points so as to effectively negotiate a resolution to the case. 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.

0m8i78

CHIEF UNITED STATES DISTRICT JUDGE

20120425

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