IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 16, 2013
UNITED STATES OF AMERICA, PLAINTIFF,
ALEXANDER G. HAMMOND, DEFENDANT.
The opinion of the court was delivered by: Hon. William B. Shubb
LAW OFFICES OF JOHNNY L. GRIFFIN III JOHNNY L. GRIFFIN III (SBN 118694) 1010 F STREET, SUITE 200 SACRAMENTO, CA 95814 Telephone: (916) 444-5557 Facsimile: (916) 444-5558 Attorney for Defendant ALEXANDER G. HAMMOND
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE DATE: May 20, 2013 TIME: 9:30 a.m. COURT: Hon. William B. Shubb
Defendant ALEXANDER G. HAMMOND, by and through his undersigned counsel, Johnny L. Griffin, III, and the United States of America, through Assistant U.S. Attorney Matthew G. Morris, hereby stipulate and request that the Court continue the status conference in the above captioned case from May 20, 2013 to July 29, 2013.*fn1 Though defense counsel has obtained a portion of military records previously requested, additional time is needed to allow the defense to obtain and review all available military medical records. The defense believes that these records are relevant and necessary to the parties negotiations in connection with finalizing the terms and conditions of the written plea agreement.
For these reasons, the parties stipulate and request that the case be continued to July 29, 2013, and that the Court exclude time within which the trial must commence under the Speedy Trial Act from May 20, 2013 through July 29, 2013, to allow for defense preparation under 18 U.S. C. § 3161(h)(8)(A) and (B)(iv).
Based on the stipulation of the parties and good cause apparent therein, the Court hereby finds that the failure to grant a continuance in this case would deny Defendants counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court specifically finds that the ends of justice are served by the granting of such continuance and outweigh the interests of the public and the Defendant in a speedy trial.
Based on these findings and pursuant to the stipulation of the parties, the Court hereby adopts the stipulation of the parties in its entirety as its order.
IT IS SO ORDERED.