Opinion
Case No. 2:11-cr-0163 DAD
09-12-2011
UNITED STATES OF AMERICA, Plaintiff, v. SARAH ANN O'NEAL, Defendant.
Respectfully submitted, DANIEL J. BRODERICK Federal Defender LINDA C. HARTER Chief Assistant Federal Defender Attorney for Defendant SARAH ANN O'NEAL KENDRA BERTSCHY Certified Student Attorney BENJAMIN B. WAGNER United States Attorney DAVID STEVENS Special Assistant U.S. Attorney Attorney for Plaintiff
DANIEL J. BRODERICK, Bar #89424
Federal Defender
LINDA C. HARTER, Bar #17 9741
Chief Assistant Federal Defender
KENDRA BERTSCHY
Certified Student Attorney
Attorney for Defendant
SARAH ANN O'NEAL
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND JURY TRIAL AND EXCLUDING TIME
JUDGE: Hon. Dale A. Drozd
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, DAVID STEVENS, Special Assistant United States Attorney, attorney for Plaintiff, and LINDA C. HARTER, Chief Assistant Federal Defender, attorney for SARAH ANN O'NEAL, and Certified Student Attorney, KENDRA BERTSCHY, that the Status Conference hearing date of September 13, 2011 be vacated, and the matter rescheduled for Status Conference on November 15, 2 011 at 10:00 a.m. It is also stipulated that the Jury Trial date of September 26, 2011 be vacated, and the matter rescheduled for Jury Trial on November 28, 2011 at 10:00 a.m.
This continuance is requested because Ms. O'Neal's counsel needs additional time to prepare, conduct additional factual investigation, and continue preliminary discussion with government's counsel toward possible resolution of the case.
To afford time to complete these tasks, the parties agree that the time under the Speedy Trial Act should be excluded from the date of signing of this order through and including November 15, 2011 pursuant to 18 U.S.C.§3161 (h)(7)(B)(iv) [reasonable time to prepare] and Local Code T4 based upon continuity of counsel and defense preparation.
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
LINDA C. HARTER
Chief Assistant Federal Defender
Attorney for Defendant
SARAH ANN O'NEAL
KENDRA BERTSCHY
Certified Student Attorney
BENJAMIN B. WAGNER
United States Attorney
DAVID STEVENS
Special Assistant U.S. Attorney
Attorney for Plaintiff
ORDER
IT IS SO ORDERED.
DALE A. DROZD
U. S. Magistrate Judge
Stip/Order/Sarah O'Neal