Opinion
CLYDE M. BLACKMON, ROTHSCHILD WISHEK & SANDS LLP, Sacramento, CA, Attorneys for Defendant, ROSS CHRISTOPHER SULLIVAN.
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
The United States of America, through its counsel Special Assistant U.S. Attorney Josh F. Sigal, and Ross Christopher Sullivan, through his counsel Clyde M. Blackmon, stipulate that the status conference now scheduled for 9:30 a.m. on October 29, 2015, shall be continued to 9:30 a.m. on December 10, 2015.
A continuance of the currently set status conference is necessary to provide the parties with more time in which to discuss a proposed plea agreement submitted to the defense by the government. The parties have met and discussed the proposed plea agreement; however, there are a number of issues that need to be worked out before the agreement can be put in final form. Therefore, the parties are in agreement that additional time is required in order to settle the case.
The parties further stipulate that the time from the currently set status conference on October 29, 2015, through December 10, 2015, the requested date for the continued status conference, should be excluded from computation of the time period in which trial should commence under the Speedy Trial Act. The parties stipulate that, taking into account the exercise of due diligence, the ends of justice would be served by the Court excluding that time period from computation due to the need for defense counsel to have reasonable time for effective preparation. 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4.
For these reasons, Mr. Sullivan, his counsel and the government stipulate and agree that the ends of justice served by granting the requested continuance of the status conference outweigh the best interests of the public and Mr. Sullivan in a speedy trial.
ORDER
IT IS ORDERED that the status conference currently set for October 29, 2015, at 9:30 a.m. is continued to December 10, 2015, at 9:30 a.m. For the reasons stipulated by the parties, good cause exists pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv), and time is excluded under the Speedy Trial Act through December 10, 2015. For the reason set forth in the stipulation of the parties, the ends of justice served by granting this continuance outweigh the best interests of the public and Mr. Sullivan in a speedy trial. 18 U.S.C. § 3161(h)(7)(B)(iv) (Local Code T4).