IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 4, 2012
UNITED STATES OF AMERICA,
RYAN ALAN RICHMOND,
BENJAMIN 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 for defendant RYAN ALAN RICHMOND be continued from May 7, 2012 to May 14, 2012 at 9:30 a.m. They stipulate that the time between May 7, 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, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T4. Specifically, the parties have reached an agreement on the basic terms of a resolution without trial, and a proposed plea agreement has been forwarded by the government and the defendant's attorney requires time to meet with the defendant and consider the terms of that agreement.
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).
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