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United States of America v. Herman Keese Deborah Barnes Marcus Law James Bradley Brett Townsend

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


May 13, 2013

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HERMAN KEESE DEBORAH BARNES MARCUS LAW JAMES BRADLEY BRETT TOWNSEND
DEFENDANTS

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER STIPULATION

Plaintiff United States of America, by and through its counsel of record, and the defendants, by and through each counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on May 16, 2013.

2. By this stipulation, the defendants now move to continue the status conference until August 8, 2013, and to exclude time between May 16, 2013 and August 8, 2013 under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery associated with this case includes approximately thousands of pages of investigative reports and related documents in electronic form. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. Counsel for the defendants desire additional time to consult with their respective clients, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with his/her client, to prepare pretrial motions, and to otherwise prepare for trial.

c. Counsel for the defendants believe that failure to grant the above-requested continuance would deny him/her the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendants in a trial within the original date prescribed by the Speedy Trial Act.

f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of May 16, 2013, to August 8, 2013, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendants in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

IT IS SO STIPULATED.

Dated: May 7, 2013 U.S. ATTORNEY by: /s/ Jill Marie Thomas JILL MARIE THOMAS Assistant U.S. Attorney Attorney for Plaintiff Dated: May 7, 2013 /s/ Christopher Booth CHRISTOPHER BOOTH Attorney for Defendant HERMAN KEESE Dated: May 7, 2013 /s/ Christopher Booth for MICHAEL CHASTAINE Attorney for Defendant DEBORAH BARNES Dated: May 7, 2013 /s/ Christopher Booth for CHRISTOPHER COSCA Attorney for Defendant MARCUS LAW Dated: May 7, 2013 /s/ CHRISTOPHER BOOTH for CLEMENTE JIMENEZ Attorney for Defendant JAMES BRADLEY Dated: May 7, 2013 /s/ Christopher Booth for DAVID FISCHER Attorney for Defendant BRETT TOWNSEND

ORDER

20130513

© 1992-2013 VersusLaw Inc.



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