The opinion of the court was delivered by: Judge: William B. Shubb
THE LAW OFFICES OF MARK J. REICHEL, State Bar MARK J. #155034 455 CAPITOL MALL, REICHEL Sacramento, California 95814 3rd FLOOR, Suite 350 Telephone: (916) 498-9258 firstname.lastname@example.org FAX: (916) 441-6553 www.reichellaw.com Attorney GERARDO ARREDONDO for Defendant
STIPULATION TO CONTINUE BRIEFING THEREON SCHEDULE; ORDER
Date: January 14, 2013 Time: 9:30 a.m.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, JASON HITT, Assistant United States Attorney, attorney for Plaintiff, and MARK J. REICHEL, Esq., attorney for defendant, that the present dates for the briefing be amended as follows:
Defense filing: November 27, 2012 Government opposition: December 18, 2012 Defense reply: January 7, 2013 Hearing on motions: January 14, 2013 at 9:30 a.m.
This continuance is requested as defense counsel needs adequate time to prepare for the case, and the defense is still reviewing the discovery and researching matters. As well, defense counsel will be in negotiations with the government in an effort to resolve the case.
Accordingly, all counsel and defendant agree that time under the Speedy Trial Act from the date this stipulation is lodged, through January 14, 2013 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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