Opinion
Case No.: 2:11 CR 00131 GEB
01-26-2012
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 January 27, 2012 and extending through March 23, 2012 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 thoroughly review all discovery from the Government by a qualified expert, which has now begun. Counsel for defendant has also been in four trials since October 14, 2011
The parties further request that this matter be taken off the January 27, 201, calendar and be rescheduled to March 23, 2012 at 9:00 a.m..
Respectfully submitted,
By: _______________
DANNY D. BRACE, JR.,
Attorney for
Mark Allen Cline
By:Kyle Reardon
Authorized to sign for Mr. Reardon
On January 26, 2012
KYLE REARDON
Assistant U.S. Attorney
IT IS SO ORDERED:
_______________
GARLAND E. BURRELL, JR.
United States District Judge