Opinion
Case No. 2:10-cr-00347-MCE
02-13-2013
UNITED STATES OF AMERICA, Plaintiff, v. JEREMY GACHAGO, et al., Defendant.
MICHAEL CHASTAINE Attorney for Jeremy Gachago BENJAMIN B. WAGNER United States Attorney Todd Leras Assistant U.S. Attorney
MICHAEL CHASTAINE, State Bar #121209
THE CHASTAINE LAW OFFICE
2377 Gold Meadow Way, Suite 100
Gold River, CA 95670
Telephone: 916-932-7150
Attorneys for Defendant
Jeremy Gachago
STIPULATION AND ORDER
CONTINUING STATUS CONFERNCE
It is hereby stipulated between the parties, Todd Leras, Assistant United States Attorney, and Michael Chastaine, attorney for Jeremy Gachago, that the status conference/change of plea date of Thursday, February 7, 2013 should be continued until Thursday, March 14, 2013. The continuance is necessary as counsel for Mr. Gachago is presently in trial and expects to still be in trial on the status conference/change of plea date of Thursday, February 7, 2013. The continuance is additionally necessary as the government has provided a plea agreement, but the current terms are not yet acceptable to Mr. Gachago; so counsel for Mr. Gachago must continue to engage in negotiations with the government.
IT IS STIPULATED that the period of time from the February 7, 2013 up to and including March 14, 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 negotiation of counsel 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: __________
Todd Leras
Assistant U.S. Attorney
ORDER
Having reviewed the above stipulation, and good cause appearing, IT IS HEREBY ORDERED that the status conference/change of plea scheduled for Thursday, February 7, 2013, at 9:00 a.m. be continued to Thursday, March 14, 2013, at 9:00 a.m. and that the period from February 7, 2013, to March 14, 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, it is ordered that the need for a continuance and continued negotiation of counsel outweighs the interests of the public and the defendant in a speedy trial.
______________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE