Opinion
No. 2:11-cr-510 WBS
01-20-2012
UNITED STATES OF AMERICA Plaintiff, v. STEVEN NEWLOVE, ET. AL. Defendants.
DWIGHT M. SAMUEL Attorney for Defendant STEVEN NEWLOVE MATTHEW G. MORRIS Assistant U.S. Attorney COURTNEY DIANE FEIN Attorney for Defendant RYAN ALAN RICHMOND
DWIGHT M. SAMUEL (CA BAR# 054486)
A PROFESSIONAL CORPORATION
Attorney for Defendant
Steven Newlove
STIPULATION AND ORDER [PROPOSED]
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Assistant United States Attorney Matthew G. Morris, defendant Steven Newlove through his undersigned counsel Dwight Samuel, and defendant Ryan Alan Richmond through his undersigned counsel Courtney Diane Fein, that the previously scheduled status conference date of January 23, 2012, be vacated and the matter set for status conference on March 5, 2012 at 9:30 a.m.
The reason for this request is that it is anticipated that additional discovery will be provided to counsel. Counsel will need additional time to review discovery, conduct investigation, and/or engage in other defense preparation.
The parties further agree and stipulate that the time period from the filing of this stipulation until March 5, 2012, 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 T-4, 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.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
By:_________
DWIGHT M. SAMUEL
Attorney for Defendant
STEVEN NEWLOVE
_________
MATTHEW G. MORRIS
Assistant U.S. Attorney
_________
COURTNEY DIANE FEIN
Attorney for Defendant
RYAN ALAN RICHMOND
IT IS SO ORDERED.
_________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE