) STIPULATION AND [PROPOSED] ORDER ) TO CONTINUE STATUS HEARING AND TO EXCLUDE TIME PURSUANT TO THE ) SPEEDY TRIAL ACT
It is hereby stipulated and agreed to between the United States of America through JASON HITT, Assistant U.S. Attorney, and defendant, STEPHEN CRAIG SAEGER, by and through his counsel, LEXI NEGIN, Assistant Federal Defender, that the status conference set for Monday, November 19, 2012, be continued to Monday, January 7, 2013, at 9:30 a.m.
The reason for this continuance is to allow defense counsel additional time to continue examining the possible defenses and investigating the facts of the case, and for further meetings between the parties with the goal being to resolve the case by way of a disposition.
It is further stipulated that the time period from the date of this stipulation, November 14, 2012, through and including the date of the new status conference hearing, January 7, 2013, shall be excluded under the Speedy Trial Act (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, and that the ends of justice to be served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial.
Respectfully submitted, BENJAMIN B. WAGNER DANIEL J. BRODERICK United States Attorney Federal Defender By: /s/ Lexi Negin for /s/ Lexi Negin JASON HITT LEXI NEGIN Assistant U.S. Attorney Assistant Federal Defender Attorney for United States Attorney for Defendant STEPHEN CRAIG SAEGER
Based on the reasons set forth in the stipulation of the parties filed on November 14, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDERED that the status conference currently scheduled for Monday, November 19, 2012, be vacated and that the case be set for Monday, January 7, 2013, at 9:30 a.m. The Court finds that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that, for the reasons stated in the parties' November 14, 2012, stipulation, the time within which the trial of this matter must be commenced under the Speedy Trial Act is excluded during the time period from the date of this stipulation, November 14, 2012, through and including January 7, 2013, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) [reasonable time to prepare] and Local Code T4.
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