IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
October 11, 2012
UNITED STATES OF AMERICA, PLAINTIFF,
CY IRVING BROWN,
SCOTT N. CAMERON Attorney at Law 1007 7th Street, Suite 319 Sacramento, California 95814 Telephone: (916) 442-5230 Attorney for: CY IRVING BROWN
STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF STATUS CONFERENCE
The parties, through undersigned counsel, stipulate that the status conference, now scheduled for October 15, 2012, may be continued to November 13, 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. However, the plea agreement has not yet been executed because the parties are trying 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 executes the plea agreement and 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.
For the reasons stated in the above stipulation of counsel, the status conference now scheduled for October 15, 2012, is continued to November 13, 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 November 13, 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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