Opinion
No. 2:05-CR-00308 EJG
01-25-2012
UNITED STATES OF AMERICA, Plaintiff, v. MARY JENNIFER BERG, Defendant.
DANIEL J. BRODERICK Federal Defender T. Zindel TIMOTHY ZINDEL Assistant Federal Defender Attorney for MARY JENNIFER BERG BENJAMIN B. WAGNER United States Attorney T. Zindel for W. Wong WILLIAM S. WONG Assistant U.S. Attorney
DANIEL J. BRODERICK, Bar #89424
Federal Defender
TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
Attorney for Defendant
MARY JENNIFER BERG
STIPULATION AND ORDER
CONTINUING STATUS CONFERENCE AND EXCLUDING TIME
Judge: Hon. Edward J. Garcia
IT IS HEREBY STIPULATED AND AGREED between defendant, Mary Jennifer Berg, through her attorney, Timothy Zindel, and plaintiff, United States of America, through its attorney, William S. Wong, that the status conference scheduled for January 27, 2012, may be continued to Friday, March 23, 2012, at 10:00 a.m.
Probation has advised the parties it needs additional time to complete investigation concerning the pre-plea presentence report ordered by the Court. They are awaiting additional documents from the government and do not expect to complete the report until mid-March. The parties need the report to finalize their plea agreement with respect to the guidelines. So that the report may be completed and reviewed, the parties ask that to continue the status conference to March 23, 2012, at 10:00 a.m. The parties further 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 March 23, 2012, pursuant to 18 U.S.C. § 3161(h)(1)(g) and (h)(7)(a) and (b)(IV).
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
T. Zindel
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for MARY JENNIFER BERG
BENJAMIN B. WAGNER
United States Attorney
T. Zindel for W. Wong
WILLIAM S. WONG
Assistant U.S. Attorney
ORDER
The status conference is continued to March 23, 2012, at 10:00 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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HON. EDWARD J. GARCIA
United States District Court