The opinion of the court was delivered by: Judge: William B. Shubb
MARK J. REICHEL, State Bar MARK J. #155034 455 CAPITOL MALL, THE LAW OFFICES OF3rd FLOOR, Suite 350 REICHEL Telephone: (916) 498-9258 Sacramento, California 95814 FAX: firstname.lastname@example.org (916) 441-6553 www.reichellaw.com Attorney ADRIANNA for Defendant
STATUS CONFERENCE STIPULATION TO CONTINUE AND REQUEST DATE FOR CHANGE OF PLEA; ORDER THEREON
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, JILL THOMAS, Assistant United States Attorney, attorney for Plaintiff, and MARK J. REICHEL, Esq., attorney for defendant, that the present dates for the status hearing be re calendared for a change of plea for November 5, 2012.
This continuance is requested as defense counsel needs adequate time to prepare for the case, and the defense is still reviewing the discovery and will be researching matters. As well, defense counsel will be in final negotiations with the government in an effort to resolve the case and the case will resolve.
Accordingly, all counsel and defendant agree that time under the Speedy Trial Act from the date this stipulation is lodged, through November 5, 2012 should be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to Title 18 U.S.C. § 3161 (H)(7)(B)(iv) and Local Code T4.
IT IS SO ORDERED. For the reasons set forth above, the court finds that there is GOOD CAUSE for the continuance and the exclusion of time, and that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial. Time is excluded pursuant to 18 U.S.C. Section 3161(h)(7)(B)(iv) and Local Code T4.
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