DWIGHT M. SAMUEL, (CA BAR# 054486) LAW OFFICE OF DWIGHT M. SAMUEL A PROFESSIONAL CORPORATION Sacramento, California, Attorney for Defendant. LEE FORD
JOHN A. MENDEZ, District Judge.
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Assistant United States Attorney Jason Hitt, and defendant Lee Ford through his undersigned counsel Dwight Samuel, , that the previously scheduled status conference date of August 27, 2013, be vacated and the matter set for status conference on October 8, 2013 at 9:45 a.m.
The reason for this request is that it is anticipated that additional discovery will be provided to counsel. Counsel will need additional time to review discovery, conduct investigation, and/or engage in other defense preparation.
The parties further agree and stipulate that the time period from the filing of this stipulation until October 8, 2013, should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
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 the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.
The Court orders that the time from the date of the parties' stipulation, August 22, 2013, to and including October 8, 2013, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B) (iv), and Local Code T4 (reasonable time for defense counsel to prepare). It is further ...