IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 4, 2012
UNITED STATES OF AMERICA,
TANEKA RAENEE NUNLEY,
The opinion of the court was delivered by: Lawrence K. Karlton Senior District Court Judge
BENJAMIN B. WAGNER United States Attorney TODD D. LERAS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2918
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE
This matter is set for a status conference and possible change of plea on May 8, 2012, at 9:15 a.m. Plaintiff United States of America and defendant Taneka Nunley, through her counsel, Attorney Dan Koukol, request the status conference/change of plea hearing date be continued to May 30, 2012.
The request is made on the ground that the parties have engaged in extensive negotiations over the terms of a final plea agreement. The government has recently adopted several terms suggested by defense counsel into a revised plea agreement.
Defense counsel needs additional time to review these changes and discuss them with his client. The parties therefore request exclusion of time under the Speedy Trial Act 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare). Dan Koukol has authorized Assistant U.S. Attorney Todd D. Leras to sign this stipulation on his behalf.
IT IS HEREBY ORDERED:
1. The status conference scheduled for May 8, 2012 is vacated.
2. A new status conference date is set for May 30, 2012, at 9:15 a.m.
3. Based on the parties' representations, the Court finds that the ends of justice outweigh the best interest of the public and Defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded through May 30, 2012.
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