DANIEL J. BRODERICK, Bar #89424 Federal Defender LEXI NEGIN, Bar # 250376 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant JENNIFER LYNN MACDOUGAL
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CHANGE OF PLEA HEARING AND TO EXCLUDE TIME
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, October 22, 2012, be vacated and a new change of plea hearing date of Tuesday, November 13, 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 November 13, 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.
Based on the reasons set forth in the stipulation of the parties filed on October 16, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDEREDthat the change of plea hearing currently scheduled for Monday, October 22, 2012, be vacated and that the case be set for Monday, November 13, 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 November 13, 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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