Opinion
No. 2:11-CR-0198 MCE
07-31-2012
UNITED STATES OF AMERICA, Plaintiff, v. CRYSTAL RUSSO, Defendant.
DANIEL J. BRODERICK Federal Defender TIMOTHY ZINDEL Assistant Federal Defender Attorney for CRYSTAL RUSSO BENJAMIN B. WAGNER United States Attorney DANIEL S. McCONKIE Assistant U.S. Attorney
DANIEL J. BRODERICK, Bar #89424
Federal Defender TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
Attorney for Defendant
CRYSTAL RUSSO
STIPULATION AND ORDER
CONTINUING STATUS CONFERENCE
AND EXCLUDING TIME
Date: August 2, 2012
Judge: Hon. Morrison C. England
IT IS HEREBY STIPULATED AND AGREED between defendant, Crystal Russo, through her attorney, Timothy Zindel, and plaintiff, United States of America, through its attorney, Daniel S. McConkie, that the status conference scheduled for August 2, 2012, may be continued to August 23, 2012, at 9:00 a.m.
Ms. Russo and counsel are still awaiting additional audio recordings the government has promised to provide in discovery. Those recordings will determine whether further investigation is needed and will help the parties to resolve the case. (The Court recently ordered a pre-plea presentence report on behalf of co-defendant Alonzo Barnett and scheduled a separate status for him.) To complete discovery and investigation, the parties agree that the ends of justice served by this continuance outweigh the best interests of the public and the defendant in a speedy trial and that time under the Speedy Trial Act should be excluded through August 23, 2012, pursuant to 18 U.S.C. § 3161(h)(1)(g) and (h)(7)(a) and (b)(IV).
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
_______________
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for CRYSTAL RUSSO
BENJAMIN B. WAGNER
United States Attorney
T. Zindel for D. McConkie
DANIEL S. McCONKIE
Assistant U.S. Attorney
ORDER
The status conference is continued to August 23, 2012, at 9:00 a.m. The Court finds that the ends of justice to be served by a continuance outweigh the best interests of the public and the defendant in a speedy trial, for the reasons stated above.
IT IS SO ORDERED.
____________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE