IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 17, 2012
UNITED STATES OF AMERICA,
JOE L. REGALADO,
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 in this case be continued from August 20, 2012, to September 17, 2012 at 9;30 a.m. They stipulate that the time between August 20, 2012, and September 17, 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 are evaluating potential exculpatory information regarding Counts Two and Three of the pending indictment, which will have a material impact on the proposed resolution of the case.
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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