Opinion
No. CR 12-00875 WHA
03-19-2013
UNITED STATES OF AMERICA, Plaintiff, v. JACQUELINE BESSER Defendant.
MELINDA HAAG (CABN 132612) United States Attorney MIRANDA KANE (CABN 150630) Chief, Criminal Division JONATHAN SCHMIDT (CABN 230646) Assistant United States Attorney Attorneys for Plaintiff
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
JONATHAN SCHMIDT (CABN 230646)
Assistant United States Attorney
Attorneys for Plaintiff
STIPULATION AND [PROPOSED] ORDER
CONTINUING HEARING DATE AND
EXCLUDING TIME
The parties are scheduled to appear on March 19, 2013. The parties request a continuance of two weeks to April 2, 2013. The parties are in plea discussions and several issues that require detailed review a economic documents have emerged. The parties anticipate that these issues will be clarified by April 2, 2013 and on that date the parties will have reached a plea agreement or ask the Court to set a trial date. The parties also ask that the time between March 19, 2013 and April 2, 2013 be excluded in calculating the time within which a trial must begin. Exclusion of time is appropriate because of the need for the parties to review documents. Failure to exclude time would deny the defendant reasonable time necessary for effective preparation, taking into account the exercise of due diligence. (18 U.S.C. § 3161(h)(B)(7)(iv)). SO STIPULATED
MELINDA HAAG
United States Attorney
________________________
JONATHAN SCHMIDT
Assistant United States Attorney
________________________
MARTHA A. BOERSCH
Attorney for Defendant
[Proposed] ORDER
GOOD CAUSE APPEARING, the status date set for March 19, 2013 is continued to April 2, 2013 and the time from March 19, 2013, to April 2, 2013 is excluded in calculating the time within which a trial must begin. (18 U.S.C. § 3161(h)(B)(7)(iv)).
IT IS SO ORDERED
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WILLIAM H. ALSUP
United States District Judge