Opinion
Case No.: 2:12 CR 0126 MCE
03-14-2013
MICHAEL CHASTAINE Attorney for Jeremy Gachago BENJAMIN B. WAGNER United States Attorney MATT MOORSE Assistant U.S. Attorney
MICHAEL CHASTAINE, State Bar #121209
THE CHASTAINE LAW OFFICE
2377 Gold Meadow Way, Suite 100
Gold River, CA 95670
Telephone: 916-732-7150
Attorneys for Defendant
Marquist Bradford
STIPULATION AND ORDER
CONTINUING STATUS CONFERNCE
It is hereby stipulated between the parties, Matt Moorse, Assistant United States Attorney, and Michael Chastaine, attorney for Marquist Bradford, that the status conference date of Thursday, March 14, 2013 should be continued until Thursday May 2, 2013. The continuance is necessary as counsel for Mr. Bradford is still reviewing discovery, meeting with the client and investigating information as well as researching various possible resolutions.
IT IS STIPULATED that the period of time from the March 14, 2013 up to and including May 2, 2013 be excluded in computing the time within which the 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. It is further stipulated that the need for a continuance and continued counsel preparation outweighs the interests of the public and the defendant in a speedy trial.
By: ____________________
MICHAEL CHASTAINE
Attorney for Jeremy Gachago
BENJAMIN B. WAGNER
United States Attorney
By: ____________________
MATT MOORSE
Assistant U.S. Attorney
ORDER
GOOD CAUSE APPEARING, in that it is the stipulation of the parties:
IT IS HEREBY ORDERED that the status conference scheduled for Thursday, March 14, 2013 at 9:00 a.m. be continued to Thursday, May 2, 2013 at 9:00 a.m. and that the period from March 14, 2013 to May 2, 2013 is excludable from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(8)(A) and local rule T4. Further, that the need for a continuance and continued counsel preparation outweighs the interests of the public and the defendant in a speedy trial.
IT IS SO ORDERED.
____________________
MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT JUDGE