December 2, 2013
United States, Plaintiff,
Jason Nathaniel Reed, et al., Defendant.
Bruce Locke (#177787), Moss & Locke, Sacramento, CA, Attorneys for Jason Nathaniel Reed.
BRUCE LOCKE, Attorney for Jason Reed.
TIMOTHY ZINDEL, Attorney for Jason Schroeder.
PHILIP COUSENS, Attorney for John Young.
CLEMENTE JIMENEZ, Attorney for Kirk Sanderson.
ERIN JOLENE RADEKIN, Attorney for David Reed.
JESSE ORTIZ, Attorney for Maribel Martinez.
JOHN D. O'CONNOR, Attorney for Joshua Roy Payne.
LINDA M. PARISI, Attorney for Andrea Lynn Turner.
JARED DOLAN, Attorney for the United States.
STIPULATION AND ORDER CONTINUING THE STATUS CONFERENCE FROM DECEMBER 2, 2013 TO MARCH 4, 2014
JOHN A. MENDEZ, District Judge.
IT IS HEREBY STIPULATED AND AGREED between the defendants, Jason Schroeder, John Young, Kirk Sanderson, Jason Reed, David Reed, Maribel Martinez, Joshua Payne, and Andrea Turner by and through their undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Jared Dolan, that the status conference presently set for December 2, 2013 at 9:45 a.m., should be continued to March 4, 2014 at 9:45 a.m., and that time under the Speedy Trial Act should be excluded from December 2, 2013 through March 4, 2014.
The reason for the continuance is the defense needs additional time to conduct pretrial investigation, including the analysis of recently provided discovery; complete potential plea negotiations; and prepare for trial. The exclusion of time is also necessary to ensure continuity of counsel. This case involves wire taps as well as numerous video tapes that need to be analyzed. Accordingly, the time between December 2, 2013 and March 4, 2014 should be excluded from the Speedy Trial calculation pursuant to Title 18, States Code, Section 3161 and Local Codes T-2 for complexity and T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Dolan has authorized Mr. Locke to sign this pleading for him.
The Court finds, for the reasons stated above, that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial, and, therefore.
IT IS SO ORDERED.