Opinion
No. CR-S-11-466 WBS
04-18-2013
THE UNITED STATES OF AMERICA, Plaintiff, v. DARREN BETZ, Defendants.
MICHAEL D. LONG Attorney for Darren Betz BENJAMIN WAGNER United States Attorney JASON HITT Assistant U.S. Attorney
MICHAEL D. LONG (CA State Bar #149475)
901 H Street, Suite 301
Sacramento, CA 95814
(916) 447-1920
Mike.Long.Law@msn.com
Attorney for DARREN BETZ
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE STATUS
CONFERENCE
Date: 6-3-13
Judge: Hon. William B. Shubb
It is hereby stipulated between the parties, Jason Hitt, Assistant United States Attorney, Michael D. Long, attorney for defendant Darren Betz, that the status conference date of April 22, 2013, should be continued until June 3, 2013 at 9:30 a.m.. The continuance is necessary because Mr. Long and Mr. Hitt are still negotiating a plea disposition and have not finalized the terms as of yet. Time has previously been excluded up until April 22, 2013, and the parties continue to jointly agree that time should continue to be excluded until June 3, 2013. Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Each party would like time to be excluded as provided by Local Code T4 from today's date through June 3, 2013.
IT IS STIPULATED that the period of time from the signing of this Order up to and including the new court date of June 3, 2013, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, for ongoing preparation of counsel. Dated: June 3, 2013
Respectfully submitted,
________________________
MICHAEL D. LONG
Attorney for Darren Betz
BENJAMIN WAGNER
United States Attorney
________________________
JASON HITT
Assistant U.S. Attorney
MICHAEL D. LONG (CA State Bar #149475)
901 H Street, Suite 301
Sacramento, CA 95814
(916) 447-1920
Mike.Long.Law@msn.com
THE UNITED STATES OF AMERICA, Plaintiff,
v.
DARREN BETZ, Defendant.
No. CR-S-11-466 WBS
ORDER
Date: 6-3-2013
Time: 9:30 a.m.
Judge: Hon. William B. Shubb
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for April 22, 2013, at 9:30 a.m. be continued to June 3, 2013, at 9:30 a.m. Based on the representations of counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case, based on the parties still negotiating the terms of a proposed plea agreement, would deny defense counsel reasonable time necessary for effective preparation, taking into account due diligence. The court finds that the reasons for granting this continuance outweigh the best interests of the public and the defendants to a speedy trial. It is ordered that time from this date to June 3, 2013, shall continue to be excluded from computation of the time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, to allow counsel time to prepare and to complete negotiations.
________________________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE