IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 10, 2012
UNITED STATES OF AMERICA, PLAINTIFF,
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 14, 2012 to June 4, 2012. They stipulate that the time between May 14, 2012 and June 4, 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 government has forwarded a proposed plea agreement and the defendant's attorney requires time to meet with the defendant and consider the terms of that agreement. In addition, the parties are evaluating the most efficient way to resolve the related case (a supervised release violation transferred from the Eastern District of Kentucky).
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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