Opinion
Case No.: 2:11 CR 0013 JAM
08-22-2011
UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY WILLIAM HUNT Defendant
Respectfully submitted, DANNY D. BRACE, JR., Attorney for Anthony William Hunt Authorized to sign for Mr. Wong On August 22, 2011 WILLIAM WONG Assistant U.S. Attorney
DANNY D. BRACE, JR., #114466
LAW OFFICE OF DANNY D. BRACE, JR.
Attorney for Anthony William Hunt
STIPULATION AND ORDER TO EXTEND TIME FOR HEARING AND TO EXCLUDE TIME
The parties agree that time beginning August 23, 2011 and extending through September 6, 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 anticipate the filing of a proposed plea agreement in this matter. 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).
The parties further request that this matter be taken off the August 23, 2011, calendar and be rescheduled to September 6, 2011 at 9:30 a.m..
Respectfully submitted,
DANNY D. BRACE, JR.,
Attorney for
Anthony William Hunt
Authorized to sign for Mr. Wong
On August 22, 2011
WILLIAM WONG
Assistant U.S. Attorney
IT IS SO ORDERED:
HON. JOHN A. MENDEZ