Opinion
Case No.: 2:11 CR 00131 GEB
09-14-2011
UNITED STATES OF AMERICA, Plaintiff, v. MARK ALLEN CLINE, Defendant
DANNY D. BRACE, JR., Attorney for Mark Allen Cline Authorized to sign for Mr. Reardon On September 13, 2011 KYLE REARDON Assistant U.S. Attorney
DANNY D. BRACE, JR., #114466
LAW OFFICE OF DANNY D. BRACE, JR.
Attorney for Mark Allen Cline
STIPULATION AND ORDER TO EXTEND
TIME FOR HEARING AND TO EXCLUDE TIME
The parties agree that time beginning August 12, 2011 and extending through September 16, 2011 should be excluded from the calculation of time under the Speedy Trial Act. (T-2 and T-4). The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and so that the defendant may have continuity of counsel. 18 U.S.C. § 3161(h)(8)(B)(iv). The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(8)(A).
More time is needed to review recently obtained additional discovery from the Government. Also, a plea agreement is being prepared based on this discovery. Additionally, counsel for Defendant is currently in trial until approximately September 27, 2011 in Sacramento County Superior Court, Department 28, in People v. James Carlton.
The parties further request that this matter be taken off the September 16, 2011, calendar and be rescheduled to October 14, 2011 at 9:00 a.m..
Respectfully submitted,
DANNY D. BRACE, JR.,
Attorney for
Mark Allen Cline
Authorized to sign for Mr. Reardon
On September 13, 2011
KYLE REARDON
Assistant U.S. Attorney
IT IS SO ORDERED:
GARLAND E. BURRELL, JR.
United States District Judge