ERIN J. RADEKIN, Attorney at Law SBN 214964, Sacramento, California, Attorney for Defendant, SEARCY ANDREWS.
BENJAMIN WAGNER, United States Attorney, RICHARD BENDER, Assistant United States Attorney.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
LAWRENCE K. KARLTON, District Judge.
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Richard Bender, and defendant, Searcy Andrews, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, January 14, 2014 at 9:15 a.m. and continue the matter to January 22, 2014 at 9:15 a.m. in the courtroom of the Honorable Lawrence K. Karlton for change of plea.
The reason for this request is that the parties need additional time to finalize the plea agreement. The government has provided a plea agreement to the defense, and Mr. Andrews has agreed to its essential terms; however, there are some details of the agreement that remain to be settled. The parties contemplate that Mr. Andrews will be prepared to change his plea on January 22, 2014. The Court is advised that Mr. Bender concurs with this request and has authorized Ms. Radekin to sign this stipulation on his behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until January 22, 2104 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 T4, 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.
IT IS SO STIPULATED.
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference of January 14, 2014 at 9:15 a.m. is VACATED and the above-captioned matter is set for change of plea on January 22, 2014 at 9:15 a.m. The court finds excludable time in this matter through January 22, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice ...