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United States of America v. Cy Irving Brown

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


August 10, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
CY IRVING BROWN,
DEFENDANT.

STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF STATUS CONFERENCE

Stipulation

The parties, through undersigned counsel, stipulate that the status conference, now scheduled for August 13, 2012, may be continued to September 4, 2012, at 9:30 a.m. The purpose of the proposed status conference was to set an evidentiary hearing on defendant's motion to suppress evidence as this Court had previously ruled that such a hearing was warranted after reviewing the briefs. However, the parties appear to have reached an agreement for resolution of this case by way of a plea agreement. The additional time requested is necessary for the government to prepare a written plea agreement and for defense counsel to review the plea agreement with the defendant.

IT IS FURTHER STIPULATED THAT time for trial under the Speedy Trial Act may be excluded pursuant to 18 U.S.C. § 3161(h)(1)(D) & (h)(7)(A) & (B)(iv), Local Codes E and T-4. The parties agree that the interests of justice served by granting this continuance outweigh the best interests of the public and defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

The prosecutor has authorized the defense counsel for Cy Brown to sign this stipulation on his behalf.

DATED: August 10, 2012 BENJAMIN WAGNER United States Attorney by /s/ Scott N. Cameron, for Jason Hitt Assistant U.S. Attorney DATED: August 10, 2012 by /s/ Scott N. Cameron Scott N. Cameron Counsel for Cy Brown Order

For the reasons stated in the above stipulation of counsel, the status conference now scheduled for August 13, 2012, is continued to September 4, 2012, at 9:30 a.m. The court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. Time for trial under the Speedy Trial Act is excluded from the date of the execution of this stipulation through September 4, 2012, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) [reasonable time to prepare], Local Code T4, and 18 U.S.C. § 3161(h)(7)(1)(D), Local Code E (commencing with the filing of motions).

20120810

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