Opinion
No. 2:11-CR-022-EFB
08-05-2011
UNITED STATES OF AMERICA, Plaintiff, v. JONI GAIL DRAKE, Defendant.
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
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
Date: September 19, 2011
Time: 10:00 a.m.
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 August 8, 2011 at 10:00 a.m. and set a status conference and change of plea hearing for September 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 September 19, 2011, pursuant to 18 U.S.C. Section § 3161(h)(7)(B)(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).
DANIEL J. BRODERICK
Federal Defender
RACHELLE BARBOUR
On behalf of 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
JUSTIN LEE
Special Assistant U.S. Attorney
ORDER
IT IS SO ORDERED.
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE