Opinion
No. 3-11-70747
11-04-2011
UNITED STATES OF AMERICA, Plaintiff, v. ROBIN O'CONNOR, Defendant.
MELINDA HAAG United States Attorney THOMAS E. STEVENS Assistant U.S. Attorney RITA BOSWORTH Attorney for Defendant Robin O'Connor
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
THOMAS E. STEVENS (CABN 168362)
Assistant United States Attorney
Attorney for the United States
STIPULATION AND [PROPOSED] ORDER CONTINUING PRELIMINARY
HEARING OR ARRAIGNMENT DATE AND WAIVING TIME
The parties request and stipulate that the date for the preliminary hearing or arraignment of defendant, Robin O'Connor, be continued from November 4, 2011, to and including November 14, 2011, on which date the parties will seek arraignment on a criminal Information filed today (November 3, 2011), under case number CR-11-0814 JW. The parties also request and stipulate that, pursuant to Federal Rule of Criminal Procedure (FRCP) 5.1(d), the time limits set forth in FRCP 5.1(c) be tolled and waived from November 4, 2011, to and including November 14, 2011.
The parties agree that - taking into account the public interest in prompt disposition of criminal cases - good cause exists for this extension. Defendant also agrees to toll and to waive for this period of time any time limits applicable under Title 18, United States Code, Section 3161.
The Court has granted three prior stipulated continuances of the preliminary hearing and arraignment and Rule 5.1(d) waivers, from July 18, 2011 to August 19, 2011, from August 19, 2011 to September 30, 2011, and from September 30, 2011, to and including November 4, 2011.
Undersigned defense counsel represents that she has spoken with her client, Ms. O'Connor, and that Ms. O'Connor agrees to the continuance and to time being tolled and waived as requested.
IT IS SO STIPULATED.
Respectfully submitted,
MELINDA HAAG
United States Attorney
THOMAS E. STEVENS
Assistant U.S. Attorney
RITA BOSWORTH
Attorney for Defendant Robin O'Connor
IT IS SO ORDERED.
JOSEPH C. SPERO
United States Magistrate Judge