Opinion
No. 2:11-CR-0198 MCE
04-09-2013
UNITED STATES OF AMERICA, Plaintiff, v. CRYSTAL RUSSO et al., Defendants.
Respectfully submitted, JOSEPH SCHLESINGER Acting 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
JOSEPH SCHLESINGER, Bar #87692
Acting 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
Date: March 14, 2013
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 March 28, 2013, may be continued to June 13, 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. Both parties expect to continue their investigation through May and would like to complete it before further scheduling. 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 13, 2013, pursuant to 18 U.S.C. § 3161(h)(1)(g) and (h)(7)(a) and (b)(IV).
Respectfully submitted,
JOSEPH SCHLESINGER
Acting Federal Defender
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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 13, 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.
IT IS SO ORDERED.
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MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT JUDGE