Opinion
No. 2:10-CR-00141 MCE
09-01-2011
UNITED STATES OF AMERICA Plaintiff, v. JENNIFER JESS Defendant
PREETI K. BAJWA Attorney for Defendant JENNIFER JESS BENJAMIN WAGNER United States Attorney SAMANTHA SPANGLER Assistant U.S. Attorney Attorney for Plaintiff
Law Offices of Preeti K. Bajwa
Preeti K. Bajwa (SBN 232484)
901 H. Street, Suite 208
Sacramento, CA 95814
(916) 444-7100
Attorney for Defendant
JENNIFER JESS
STIPULATION AND ORDER
JUDGE: Hon. Morrison England
It is hereby stipulated and agreed to between the United States of America through Samantha Spangler, Assistant U.S. Attorney, and the defendant JENNIFER JESS by and through her counsel, PREETI K. BAJWA, Attorney at Law, that the status conference set for Tuesday September 6, 2011 be continued to Thursday October 20, 2011 at 9:00 a.m.
The reason for this continuance is to allow defense counsel additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case. Additionally, Ms. Jess is presently in the process of being scheduled to undergo bariatric surgery in September 2011. This is to treat a myriad of medical problems from which Ms. Jess is suffering including chronic back, bilateral hip pain and morbid obesity.
Accordingly, the parties believe that the continuance should be excluded from the calculation of time under the Speedy Trial Act. The additional time is necessary to ensure effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4. 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).
Respectfully submitted,
PREETI K. BAJWA
Attorney for Defendant
JENNIFER JESS
BENJAMIN WAGNER
United States Attorney
SAMANTHA SPANGLER
Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
The status conference in this matter is continued from September 6, 2011 to October 20, 2011. Time is excluded from today's date through and including October 20, 2011 in the interests of justice pursuant to 18 U.S.C. section 3161(h)(7)(B)(iv) [reasonable time to prepare] and Local Code T4. The Court specifically finds that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial.
IT IS SO ORDERED.
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE