HEATHER E. WILLIAMS, #122664 Federal Defender, BENJAMIN D. GALLOWAY, #214897 Assistant Federal Defender, Designated Counsel for Service Sacramento, California, Attorney for Defendant. MANDY RICE
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME
GARLAND E. BURRELL, Jr., Senior District Judge.
IT IS HEREBY STIPULATED and agreed to by United States of America through Assistant United States Attorney JARED DOLAN and BENJAMIN GALLOWAY Assistant Federal Defender, attorney for defendant, MANDY RICE that the status conference set for Friday, August 30, 2013 be continued to Friday, October 11, 2013 at 9:00 a.m.
The reason for this continuance is that previous defense counsel, Assistant Federal Defender Angeles Zaragoza has left the office and Assistant Federal Defender Benjamin Galloway has recently been assigned to represent Ms. Rice. Additional time is needed to allow new defense counsel time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case.
The parties stipulate that the ends of justice served by the granting of such continuance outweigh the interests of the public and the defendant in a speedy trial.
Speedy trial time is to be excluded from the date of this order through the date of the status conference set for October 11, 2013, pursuant to 18 U.S.C. § 3161 (h)(7)(A) and (B)(iv) [reasonable time to prepare] (Local Code T4).
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. The Court specifically finds that the failure to grant a continuance in this case would deny 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 defendant in a speedy trial.
The Court orders that the time from the date of the parties stipulation, up to and including October 11, 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)[reasonable time for counsel to prepare] (Local Code T4). It is further ordered ...