Opinion
No. CR 13-024 WHA (NJV)
03-25-2013
UNITED STATES OF AMERICA, v. ROLAND LEROY RAYMOND, Defendant.
MELINDA HAAG (CABN 132612) United States Attorney MIRANDA KANE (CABN 150630) Chief, Criminal Division DAVID R. CALLAWAY (CABN 121782) Assistant United States Attorney Attorneys for Plaintiff RANDALL H. DAVIS, ESQ. Counsel for Defendant
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
DAVID R. CALLAWAY (CABN 121782)
Assistant United States Attorney
Attorneys for Plaintiff
STIPULATION CONTINUING
DATE FOR CHANGE OF PLEA;
ORDER [proposed]
Date: March 26, 2013
Before The Hon. William H. Alsup
The United States, through its counsel, Assistant United States Attorney David R. Callaway, and defendant Roland Leroy Raymond, by and through his attorney, Randall H. Davis, Esq., are unfortunately back again to request and stipulate that the defendant's first appearance before the District Court - which will be a change of plea - be continued from Tuesday, March 26, 2013, to Tuesday, April 23, 2013, at 2:00 p.m., before The Honorable William H. Alsup, United States District Judge. This time the basis for the continuance is to accommodate the defendant's schedule: Mr. Raymond does not have transportation from Eureka to San Francisco on March 26th. (He does not have a valid driver's license and his wife, who would normally drive him, is out of town next week.) The next available court date when all parties can be in San Francisco is April 23rd.
The parties further agree that the time occasioned by this continuance is appropriately excluded from the Speedy Trial Clock based on the need for effective defense preparation and continuity of defense counsel, and in light of the facts set forth in this stipulation. 18 U.S.C. § § 3161(h)(7)(A) and (B)(i) and (iv)..
The parties apologize to the Court for submitting a new stipulation only a few days after the last one, but it could not be helped.
Respectfully submitted,
MELINDA HAAG
United States Attorney
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DAVID R. CALLAWAY
Assistant United States Attorney
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RANDALL H. DAVIS, ESQ.
Counsel for Defendant
ORDER [proposed]
Based on the parties' stipulation, and for good cause shown,
IT IS HEREBY ORDERED that the first appearance in District Court for defendant Roland Leroy Raymond in the captioned matter is rescheduled to Tuesday, April 23, 2013, at 2:00 p.m., before The Honorable William H. Alsup, United States District Judge.
IT IS HEREBY FURTHER ORDERED that the 28 days between March 26 and April 23, 2013, are excluded from the Speedy trial clock based on the need for effective defense preparation and continuity of defense counsel, and in light of the facts set forth in the stipulation. 18 U.S.C. § § 3161(h)(7)(A) and (B)(i) and (iv).
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WILLIAM H. ALSUP
United States District Judge