United States District Court, N.D. California, San Francisco Division
February 13, 2014
UNITED STATES OF AMERICA,
BRADY BELL, et al., Defendant.
MELINDA HAAG, United States Attorney, J. DOUGLAS WILSON, Chief, Criminal Division, ACADIA L. SENESE, Assistant United States Attorney, San Francisco, California, Attorneys for United States of America.
GAIL SHIFMAN, Counsel for Mr. Brady Bell.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE CHANGE OF PLEA HEARING
JON S. TIGAR, District Judge.
The above-captioned matter is set on February 14, 2014 at 2:00 p.m. before this Court for a change of plea. However, despite the parties' best efforts to resolve this matter expeditiously, the parties need additional time to confer and the government needs additional time to secure the requisite approvals for a proposed disposition. Undersigned counsel conferred with the Court's deputy clerk and the earliest next available date that is agreeable to all a parties is March 28, 2014 at 9:30 a.m., Accordingly, the parties hereby stipulate to continue the status conference from February 14, 2014 to March 28, 2014 at 9:30 a.m.
The parties further stipulate and agree that the ends of justice served by this continuance outweigh the best interest of the public and the defendant in a speedy trial. The parties agree that the failure to grant this continuance would unreasonably deny defendant effective preparation of counsel. Accordingly, the parties agree that the period of time from February 14, 2014 to March 28, 2014 should be excluded in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A).
Based on the reasons provided in the stipulation of the parties above, IT IS HEREBY ORDERED that the hearing date of February 14, 2014, scheduled at 2:00 p.m., is vacated and reset to March 28, 2014, at 9:30 a.m. for a change of plea hearing. It is FURTHER ORDERED that time is excluded pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A), from February 14, 2014 to March 28, 2014, for effective preparation of counsel.