TASHA PARIS CHALFANT (SBN 207055), THE LAW OFFICES OF TASHA PARIS CHALFANT, Rocklin, California, Attorney for Defendant, DAYNA LYN HUNTSMAN.
CHRISTIAAN HIGHSMITH, Assistant U.S. Attorney, Attorney for the United States.
STIPULATION REGARDING CONTINUANCE OF INITIAL APPEARANCE/REVOCATION; FINDINGS AND ORDER THEREON
MORRISON C. ENGLAND, Chief District Judge.
Plaintiff United States of America, by and through its counsel of record, and the defendant, by and through his counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for an Initial Appearance/Revocation hearing on April 11, 2013. By the court's own motion, the matter was continued to May 9, 2013.
2. By this stipulation, the defendant now moves to continue the Initial Appearance/Revocation hearing until June 13, 2013. Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. Counsel for the defendant desires additional time to consult with her client, to review the current charges and to discuss the charges pending in state court with the state court lawyer who has indicated the preliminary hearing is scheduled later this month. Those charges are the basis for the revocation hearing and all counsel need to coordinate any in custody issues and potential resolutions between the state and federal matters.
b. Counsel for the defendant believes that failure to grant the above-requested continuance would deny her the reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and allow for the state court matter upon which this revocation is based to potentially resolve.
c. The government does not object to the continuance.
d. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interests of the defendant and the public to a speedy trial.
IT IS SO ...