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United States v. Moses

United States District Court, Ninth Circuit

January 28, 2014

UNITED STATES OF AMERICA, Plaintiff,
v.
HEATHER MOSES, Defendant,

Jared Dolan, Assistant United States Attorney.

SCOTT N. CAMERON, (SBN 226605), Attorney at Law, Sacramento, CA, Attorney for HEATHER MOSES.

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER

TROY L. NUNLEY, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel of record, and defendant HEATHER MOSES, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on January 30, 2014, at 9:30 a.m.

2. By this stipulation, defendant now moves to continue the status conference until March 20, 2014, at 9:30 a.m., and to exclude time between January 30, 2014, and March 20, 2014, under Local Code T4. 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, 500 pages of discovery to the defense.

b. Defense counsel desires additional time to review the document discovery, consult with his client regarding the discovery, conduct investigation, and to discuss potential resolution with his client and the government.

c. The parties have been involved in negotiations which have been fruitful and the parties desire additional time to conclude those negotiations.

d. Counsel for each defendant 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 ...


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