Opinion
No. 2:11-cr-00190 MCE
08-24-2011
UNITED STATES OF AMERICA, Plaintiff, v. NICHOLAS RAMIREZ TIFFANY BROWN, Defendants.
DINA L. SANTOS Attorney for Tiffany Brown MICHAEL BIGELOW Attorney for Jason Hitt JASON HITT Assistant United States Attorney Attorney for Plaintiff
DINA L. SANTOS, Bar #204200
A Professional Law Corporation
Attorney for Defendant
TIFFANY BROWN
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
Judge: Hon. England
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Jason Hitt, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant Tiffany Brown; Attorney Michael Bigelow, Counsel for Nicholas, that the status conference scheduled for August 25, 2011, be vacated and the matter be continued to this Court's criminal calendar on October 27,2011,at 9:00 a.m. for further status.
This continuance is requested by the defense in order to permit counsel to continue in negotiations with the prosecution in attempt to reach a resolution, meet with the clients to discuss various resolutions, and to review continue the defense investigation.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.
The Court is advised that all counsel have conferred about this request, that they have agreed to the October 27, 2011 date, and that all counsel have authorized Ms. Santos to sign this stipulation on their behalf.
IT IS SO STIPULATED.
DINA L. SANTOS
Attorney for
Tiffany Brown
MICHAEL BIGELOW
Attorney for
Jason Hitt
JASON HITT
Assistant United States Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE