Opinion
Case No.: 2:11 CR 00131 GEB
10-12-2011
UNITED STATES OF AMERICA, Plaintiff, v. MARK ALLEN CLINE, Defendant
DANNY D. BRACE, JR., #114466 LAW OFFICE OF DANNY D. BRACE, JR. Attorney for Mark Allen Cline
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 October 14, 2011 and extending through November 18, 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. Counsel for defendant has been in Trial. Also, a plea agreement has been prepared based on this discovery.
The parties further request that this matter be taken off the October 14, 2011, calendar and be rescheduled to November 18, 2011 at 9:00 a.m..
Respectfully submitted,
DANNY D. BRACE, JR.
Attorney for
Mark Allen Cline
By: Kyle Reardon
Authorized to sign for Mr. Reardon
On October 11, 2011
KYLE REARDON
Assistant U.S. Attorney
IT IS SO ORDERED:
GARLAND E. BURRRELL, JR.
United States District Judge