Opinion
No. 2:11-cr-0198 MCE
06-13-2013
UNITED STATES OF AMERICA, Plaintiff, v. CRYSTAL RUSSO et al., Defendants.
HEATHER E. WILLIAMS Federal Defender TIMOTHY ZINDEL Assistant Federal Defender Attorney for CRYSTAL RUSSO BENJAMIN B. WAGNER United States Attorney DANIEL S. McCONKIE Assistant U.S. Attorney
HEATHER E. WILLIAMS, Bar #122664
Federal Defender
TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
CRYSTAL RUSSO
STIPULATION AND ORDER
CONTINUING STATUS CONFERENCE
AND EXCLUDING TIME
Judge: Hon. Morrison C. England
IT IS HEREBY STIPULATED AND AGREED between defendant, Crystal Russo, through her attorney, Timothy Zindel, and plaintiff, United States of America, through its attorney, Daniel S. McConkie, that the status conference as to defendant Russo, scheduled for June 13, 2013, may be continued to June 27, 2013, at 9:00 a.m.
The government has requested additional time to investigate Ms. Russo's defense to the charges. Counsel met during the week of March 18 to discuss the defense investigation and provide information relative to Ms. Russo's defense. The government has yet to advise defense counsel about how it wishes to proceed. The parties therefore agree that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial and that time under the Speedy Trial Act should be excluded through June 27, 2013, pursuant to 18 U.S.C. § 3161(h)(1)(g) and (h)(7)(a) and (b)(IV).
Respectfully submitted,
HEATHER E. WILLIAMS
Federal Defender
____________________
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for CRYSTAL RUSSO
BENJAMIN B. WAGNER
United States Attorney
T. Zindel for D. McConkie
DANIEL S. McCONKIE
Assistant U.S. Attorney
ORDER
The status conference is continued to June 27, 2013, at 9:00 a.m. The Court finds that the ends of justice to be served by a continuance outweigh the best interests of the public and the defendant in a speedy trial, for the reasons stated above, and orders time excluded through the status conference on June 27, 2013.
IT IS SO ORDERED.
________________________________________
MORRISON C. ENGLAND , JR., CHIEF JUDGE
UNITED STATES DISTRICT COURT