STIPULATION AND [PROPOSED] ORDER CONFERENCE FOR CONTINUANCE OF STATUS
The parties, through undersigned counsel, stipulate that the status conference, now scheduled for September 17, 2012, may be continued to October 1, 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 to allow the parties to resolve a remaining forfeiture issue prior to defendant entering a change of plea. Because the proposed plea agreement specifically addresses certain forfeiture claims, this final issue must be resolved before defendant changes his plea.
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: September 12, 2012 BENJAMIN WAGNER United States Attorney by /s/ Scott N. Cameron, for Jason Hitt Assistant U.S. Attorney DATED: September 12, 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 September 17, 2012, is continued to October 1, 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 October 1, 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).
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