Opinion
Cr.S. 12-0447-GEB
03-15-2013
UNITED STATES OF AMERICA, Plaintiff, v. MANDY RICE, Defendant.
ANGELES ZARAGOZA Assistant Federal Defender Attorney for Defendant BENJAMIN WAGNER United States Attorney JARED DOLAN Assistant U.S. Attorney Attorney for Plaintiff
JOSEPH SCHLESINGER, Bar# 87692
Acting Federal Defender
ANGELES ZARAGOZA, #270198
Assistant Federal Defender
Designated Counsel for Service
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
MANDY RICE
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS CONFERENCE AND
EXCLUDE TIME
DATE: April 12, 2013
JUDGE: Hon. Garland E. Burrell
IT IS HEREBY STIPULATED and agreed to by United States of America through Assistant United States Attorney JARED DOLAN and ANGELES ZARAGOZA Assistant Federal Defender, attorney for defendant, MANDY RICE that the status conference set for Friday, March 15, 2013 be continued to Friday, April 12, 2013 at 9:00 a.m.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case.
The parties stipulate that the ends of justice served by the granting of such continuance outweigh the interests of the public and the defendant in a speedy trial.
Speedy trial time is to be excluded from the date of this order through the date of the status conference set for April 12, 2013, pursuant to 18 U.S.C. § 3161 (h)(7)(B)(iv) [reasonable time to prepare] (Local Code T4).
AGREED:
JOSEPH SCHLESINGER
Acting Federal Defender
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ANGELES ZARAGOZA
Assistant Federal Defender
Attorney for Defendant
BENJAMIN WAGNER
United States Attorney
___________
JARED DOLAN
Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. The Court specifically finds that the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and defendant in a speedy trial.
The Court orders that the time from the date of the parties stipulation, up to and including April 12, 2013, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) T4 (reasonable time for counsel to prepare). It is further ordered that the March 15, 2013 status conference shall be continued until April 12, 2013, at 9:00 a.m.
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GARLAND E. BURRELL, JR.
Senior United States District Judge