IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
November 14, 2012
UNITED STATES OF AMERICA,
The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY STIPULATED by and between Plaintiff United States of America, by and through Assistant United States Attorney Todd D. Leras, and Attorney Michael Chastaine on behalf of Defendant Jeremy Gachago, that the status conference scheduled for November 8, 2012, be continued to December 6, 2012, at 9:00 a.m.
The parties are continuing to work toward resolution of the case. A proposed plea agreement has been provided to defense counsel. Defense counsel has proposed a potential alternative resolution and needs additional time to present information to the government in support of the counter proposal.
To accomplish this process the parties are continuing with investigation in this case, which involves wiretap interceptions. The parties therefore request to continue the status conference to December 6, 2012.
For the above-stated reasons, the parties stipulate that time be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4 (reasonable time to prepare and continuity of counsel). Defense counsel has authorized Assistant U.S. Attorney Todd D. Leras to sign this stipulation on his behalf.
DATED: November 7, 2012 By: /s/ Todd D. Leras TODD D. LERAS Assistant U.S. Attorney DATED: November 7, 2012 By: /s/ Todd D. Leras for MICHAEL CHASTAINE Attorney for Defendant JEREMY GACHAGO
IT IS HEREBY ORDERED:
1. A status conference in this matter, currently scheduled for November 8, 2012, is hereby vacated and continued to December 6, 2012, at 9:00 a.m. in Courtroom 7;
2. Based on the stipulation of the parties, the Court finds that the ends of justice outweigh the best interest of the public and Defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare) up to and including December 6, 2012.
IT IS SO ORDERED
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