Opinion
Case No. 2:11-cr-00190-MCE
01-24-2012
UNITED STATES OF AMERICA, Plaintiff, v. NICHOLAS RAMIREZ, TIFFANY BROWN Defendant
MICHAEL B. BIGELOW Attorney at Law Attorney for Defendant Nicholas Ramirez
MICHAEL B. BIGELOW
Attorney at Law
Attorney for Defendant
Nicholas Ramirez
STIPULATION AND ORDER
CONTINUING STATUS AND EXCLUDING
TIME
Date: March 29, 2012
Court: MCE
ORDER
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Jason Hitt, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant Tiffany Brown; Attorney Michael Bigelow, Counsel for Nicholas, that the status conference scheduled for January 26, 2012 at 9:00 AM, be vacated and the matter be continued to this Court's criminal calendar on March 29, 2012, at 9:00 a.m. for further status.
This continuance is requested by the defense in order to permit counsel to continue in negotiations with the prosecution in an effort to reach resolution and to prepare for defense of this case.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161, et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial. The Court is advised that all counsel have conferred about this request, that they have agreed to the March 29, 2012 date, and that all counsel have authorized Mr. Bigelow to sign this stipulation on their behalf.
IT IS SO STIPULATED.
________________________
Jason Hitt, Esq.,
Assistant United States Attorney
Attorney for Plaintiff
________________________
Michael B. Bigelow
Attorney for Defendant
Nicholas Ramirez
________________________
Dina Santos
Attorney for Defendant
Tiffany Brown
IT IS SO ORDERED.
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MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE