IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 15, 2012
UNITED STATES OF AMERICA,
JENNIFER LYNN MACDOUGAL,
The opinion of the court was delivered by: Judge: William B. Shubb
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CHANGE OF PLEA HEARING AND TO EXCLUDE
TIME Date: September 24, 2012 Time: 9:30 a.m.
Judge: William B. Shubb
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Jason Hitt, Assistant United States Attorney, and Lexi Negin, Assistant Federal Defender, attorney for defendant JENNIFER LYNN MACDOUGAL, that the change of plea hearing scheduled for Monday, August 20, 2012, be vacated and a new change of plea hearing date of Monday, September 24, 2012, at 9:30 a.m.,be set.
The reason for this continuance is because a proposed plea agreement is forthcoming from the government, and defense counsel needs additional time to review the plea agreement with the client once it is received.
It is further stipulated that the time for trial under the Speedy Trial Act should be excluded from the date of the signing of this order through and including September 24, 2012, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) [reasonable time to prepare] and Local Code T4, and that the ends of justice to be served by granting the continuance outweigh the best interest of the public and the defendant to a speedy trial. Dated: August 14, 2012
Respectfully submitted, DANIEL J. BRODERICK Federal Defender /s/ Lexi
Negin LEXI NEGIN Assistant Federal Defender Attorney for Defendant
Dated: August 14, 2012
BENJAMIN B. WAGNER
United States Attorney /s/ Lexi Negin for JASON HITT Assistant U.S.
Based on the reasons set forth in the stipulation of the parties filed on August 15, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDERED that the change of plea hearing currently scheduled for Monday, August 20, 2012, be vacated and that the case be set for Monday, September 24, 2012, at 9:30 a.m. The Court finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that the time within which the trial of this matter must be commenced under the Speedy Trial Act is excluded during the time period of today's date, through and including September 24, 2012, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) and Local Code T4, due to the need to provide defense counsel with the reasonable time to prepare taking into account due diligence.
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