Michael E. Hansen, Attorney at Law, SBN 191737, Sacramento, CA, Attorney for Defendant, JAYMAR BROWN.
SHARI RUSK, Attorney for Defendant, MICHELLE WRIGHT.
CANDACE FRY, Attorney for Defendant, JANEIGH MENDOZA.
ERIN RADEKIN, Attorney for Defendant, KENNETH WRIGHT.
BENJAMIN B. WAGNER, United States Attorney, JARED DOLAN, Assistant U.S. Attorney Attorney for Plaintiff.
AMENDED STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE/CHANGE OF PLEA HEARING, AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
LAWRENCE K. KARLTON, District Judge.
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Jared Dolan, Assistant United States Attorney, attorney for plaintiff; Shari Rusk, attorney for defendant Michelle Wright; Candace Fry, attorney for defendant Janeigh Mendoza; Erin Radekin, attorney for defendant Kenneth Wright; and Michael Hansen, attorney for defendant Jaymar Brown, that the previously-scheduled status conference/change of plea hearing date of August 6, 2013, be vacated and the matter set for status conference on August 27, 2013, at 9:15 a.m.
This continuance is requested because Mr. Hansen was recently reappointed and needs additional time to continue plea negotiations.
The Government concurs with this request.
Further, the parties agree and stipulate the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendants in a speedy trial and that time within which the trial of this case must be commenced under the Speedy Trial Act should therefore be excluded under 18 U.S.C. section 3161(h)(7)(B)(iv), corresponding to Local Code T-4 (to allow defense counsel time to prepare), from the date of the parties' stipulation, August 1, 2013, to and including August 27, 2013.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED.
The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. Based on the stipulation of the parties and the recitation of facts contained therein, the Court finds that it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in 18 U.S.C. section 3161. In addition, the Court specifically finds that the failure to grant a continuance in this case would deny defense counsel to this stipulation reasonable time necessary for effective preparation, taking into account the exercise of due ...