Opinion
Case No.: 2:11 CR 0324 JAM
10-03-2011
The CHASTAINE LAW OFFICE By: MICHAEL CHASTAINE Attorney for David Reyes Navarro LAWRENCE BROWN Acting United States Attorney By: Jared Dolan Assistant U.S. Attorney
MICHAEL CHASTAINE, State Bar #121209
THE CHASTAINE LAW OFFICE
Attorneys for Defendant
JIMMY HATCHER
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
Defendant JIMMY HATCHER, by and through his attorney, Michael Chastaine and the United States, by and through Assistant United States Attorney Jared Dolan, hereby stipulate and agree to continue the sentencing hearing in the above-captioned case from Tuesday, October 04 2011 at 9:30 a.m. to Tuesday, December 13, 2011 at 9:30 a.m. It is further stipulated that the above referenced time period should be excluded from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(8)(A) and local rules T4.The continuance is requested to review the large amount of discovery that has been provided and additional discovery that is expected to be provided.
The parties further agree and stipulate that the time period from the filing of this Stipulation until December 13, 2011 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
The CHASTAINE LAW OFFICE
By: MICHAEL CHASTAINE
Attorney for David Reyes Navarro
LAWRENCE BROWN
Acting United States Attorney
By: Jared Dolan
Assistant U.S. Attorney
ORDER
GOOD CAUSE APPEARING, in that it is the stipulation of the parties:
IT IS HEREBY ORDERED that the status conference scheduled for Tuesday October 04, 2011 at 9:30 a.m. be continued to Tuesday December 13, 2011 at 9:30 a.m. and that the period from October 4, 2011 to December 13, 2011 is excludable from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(8)(A).
Judge John A. Mendez
District Judge
United States District Court