Opinion
No. CRS 06 0441 GEB
08-25-2011
Timothy E. Warriner Attorney at Law Attorney for defendant, AARON POTTS Jill Thomas, Assistant United States Attorney, for the Government
Timothy E. Warriner
Attorney at Law
Attorney for defendant,
AARON POTTS
STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF
STATUS CONFERENCE AND FOR EXCLUSION OF TIME
Counsel for the government, Jill Thomas, and counsel for defendant Aaron Potts, Timothy E. Warriner, hereby jointly request that the status conference now scheduled for August 26, 2011, be continued to September 30, 2011 at 9:00 a.m., and that time continue to be excluded to September 30, 2011 for preparation of counsel (Local Code T 4; 18 U.S.C. § 3161(h)(7)(B)(iv)). Exclusion of time is requested as additional time is needed for counsel to review and evaluate the pre-plea presentence report and written plea agreement, to meet with the client, who is housed in the Butte County Jail, concerning the pre-plea report and plea agreement, and to continue plea negotiations with the Government. The parties stipulate that the ends of justice served by this continuance outweigh the best interest of the public and the defendant in a speedy trial.
Respectfully submitted.
Tim Warriner, Attorney for
Defendant, Aaron Lamar Potts
Jill Thomas, Assistant United
States Attorney, for the Government
[PROPOSED] ORDER
Pursuant to the stipulation of the parties, it is hereby ordered that the status conference set for August 26, 2011 be continued to September 30, 2011 at 9:00 a.m., and that time continue to be excluded to September 30, 2011 for preparation of counsel (Local Code T 4; 18 U.S.C. § 3161(h)(7)(B)(iv)). The court finds that the ends of justice served by the granting of the continuance outweigh the best interests of the public and the defendant in a speedy trial. (18 U.S.C. § 3161(h)(7)(A).)
GARLAND E. EURRELL, JR.
United States District Judge