Opinion
No. 2:11-CR-022-EFB
10-17-2011
UNITED STATES OF AMERICA, Plaintiff, v. JONI GAIL DRAKE, Defendant.
DANIEL J. BRODERICK Federal Defender LINDA C. HARTER Chief Assistant Federal Defender Attorney for Defendant JONI GAIL DRAKE KENDRA BERTSCHY Certified Law Student BENJAMIN B. WAGNER United States Attorney JUSTIN LEE Special Assistant U.S. Attorney
DANIEL J. BRODERICK, #89424
Federal Defender
LINDA C. HARTER, CA Bar #179741
Chief Assistant Federal Defender
Designated Counsel for Service
KENDRA BERTSCHY
Certified Student Attorney
Attorney for Defendant
JONI GAIL DRAKE
STIPULATION TO CONTINUE AND EXCLUDE TIME
Judge: Hon. Edmund F. Brennan
IT IS HEREBY STIPULATED between the parties through their respective counsel, Justin Lee, Special Assistant United States Attorney, and Linda C. Harter, Chief Assistant Federal Defender, attorney for JONI GAIL DRAKE, and Certified Student Attorney, Kendra Bertschy, that the Court vacate the status conference and change of plea hearing on October 18, 2011 at 10:00 a.m. and set a status conference and change of plea hearing for December 19, 2011 at 10:00 a.m.
This continuance is requested because the parties are in the process of plea negotiation. The parties need more time to reach a plea agreement. The parties further agree that the time should be excluded from the date of this [Proposed] Order until the Change of Plea Hearing which is set for December 19, 2011, pursuant to 18 U.S.C. Section § 3161(h)(7)(A)(iv) and Local Code T4 (reasonable time to prepare). 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)(7)(A)(iv)11.
DANIEL J. BRODERICK
Federal Defender
LINDA C. HARTER
Chief Assistant Federal Defender
Attorney for Defendant
JONI GAIL DRAKE
KENDRA BERTSCHY
Certified Law Student
BENJAMIN B. WAGNER
United States Attorney
JUSTIN LEE
Special Assistant U.S. Attorney
ORDER
IT IS SO ORDERED.
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE