The opinion of the court was delivered by: Judge: William B. Shubb
DANIEL J. BRODERICK, Bar# 89424 Federal Defender MATTHEW C. BOCKMON, Bar# 161566 Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone (916) 498-5700 Attorney for Defendant JENNIFER BROWN
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
DATE: January 7, 2013
TIME: 9:30 a.m.
It is hereby stipulated and agreed to between the United States of America through Jared C. Dolan, Assistant U.S. Attorney, and defendants, MICHELLE WRIGHT by and through her counsel, Shari Rusk, JANEIGH MENDOZA by and through her counsel, Candace Anne Fry, KENNETH WRIGHT by and through his counsel, Timothy E. Warriner, JAYMAR BROWN by and through his counsel, Michael E. Hansen, BRANDY MINER by and through her counsel, Olaf William Hedberg and JENNIFER BROWN by and through her counsel, Matthew C. Bockmon, Assistant Federal Defender, that the status conference hearing date of November 19, 2012, be vacated and a new status conference hearing date of Monday, January 7, 2013, at 9:30 a.m., be set.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendants, to examine possible defenses, and to continue investigating the facts of the case. It is further stipulated and agreed between the parties that the time period from November 14, 2012, through and including the date of the new status conference hearing, January 7, 2013, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 [reasonable time for defense counsel to prepare].
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) and Local Code T4.
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