Opinion
HAYES H. GABLE, III, Attorney at Law, Sacramento, CA.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT
GARLAND E. BURRELL, Jr., Senior District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Todd Pickles, and defendant Jodene Margaret Watt, by and through her attorney of record, Hayes H. Gable III, agree and stipulate to vacate the existing status conference in the above-entitled case, April 17, 2015, and to continue the matter to June 12, 2015, at 9:00 a.m., for status conference.
The parties further agree and stipulate that the period from April 17, 2015 to June 12, 2015, should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 USC §§3161(h)(7)(A) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation.
It is further agreed and stipulated that the need for defense counsel to prepare exceeds the defendant's and the public's interest in commencing trial within the 70-day Speedy Trial time period.
Accordingly, the parties request the Court to adopt this stipulation.
ORDER
IT IS SO ORDERED.