SCOTT N. CAMERON (SBN 226605) Attorney at Law, Sacramento, CA, Attorney for MICHAEL HUDDLESTON.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendant MICHAEL HUDDLESTON, by and through his counsel of record, Scott N. Cameron hereby stipulate as follows:
1. By previous order, this matter was set for status on October 24, 2013, at 9:30 a.m.
2. By this stipulation, defendant HUDDLESTON now moves to continue the status conference to December 12, 2013, at 9:30 a.m., and to exclude time between October 24, 2013, and December 12, 2013, under Local Code T4. This motion to continue the status conference by stipulation does include defendant Brent Wilder. Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. The government has produced approximately 2, 830 pages of discovery to the defense.
b. Counsel for defendant HUDDLESTON desires additional time to review the document discovery, consult with the client regarding the discovery, conduct investigation, and to discuss potential resolution with their client and the government.
c. Counsel for the defense and the government have been involved in substantive settlement negotiations which are still in progress. The government provided defendant HUDDLESTON with a plea agreement on October 21, 2013, and defense counsel needs the additional time to review the plea agreement with the client.
d. Counsel for defendant HUDDLESTON believes that failure to grant the above-requested continuance would deny defendants the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
e. The government does not object to the continuance.
f. 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 defendant in a trial within the original date prescribed by the Speedy Trial Act.
g. 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 October 24, 2013, to December 12, 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 ...