Opinion
CASE NO. CR-S-11-501 WBS
01-24-2012
UNITED STATES OF AMERICA, Plaintiff, v. STEPHEN CRAIG SAEGER, Defendant.
Respectfully submitted, BENJAMIN B. WAGNER United States Attorney Lexi Negin for JASON HITT Assistant U.S. Attorney Attorney for United States DANIEL J. BRODERICK Federal Defender LEXI NEGIN Assistant Federal Defender Attorney for Defendant STEPHEN CRAIG SAEGER
DANIEL J. BRODERICK, Bar #89424
Federal Defender
Lexi Negin, Bar #250376
Assistant Federal Defender
Attorney for Defendant
STEPHEN CRAIG SAEGER
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS HEARING AND TO
EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
Judge: William B. Shubb
It is hereby stipulated and agreed to between the United States of America through JASON HITT, Assistant U.S. Attorney, and defendant, STEPHEN CRAIG SAEGER, by and through his counsel, LEXI NEGIN, Assistant Federal Defender, that the status conference set for Monday, January 30, 2012, be continued to Monday, March 19, 2012, at 9:30 a.m.
The reason for this continuance is because additional time is needed for defense preparation and meetings between the parties with the goal being to resolve the case by way of a disposition.
It is further stipulated that the time period from the date of this stipulation, January 24, 2012, through and including the date of the new status conference hearing, March 19, 2012, shall be excluded under the Speedy Trial Act (18 U.S.C. §3161(h)(7)(A) &(B)(iv) and Local Code T4, due to the need to provide defense counsel with the reasonable time to prepare, and that the ends of justice to be served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial.
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: ____________
Lexi Negin for
JASON HITT
Assistant U.S. Attorney
Attorney for United States
DANIEL J. BRODERICK
Federal Defender
____________
LEXI NEGIN
Assistant Federal Defender
Attorney for Defendant
STEPHEN CRAIG SAEGER
ORDER
Based on the reasons set forth in the stipulation of the parties filed on January 24, 2012, and good cause appearing therefrom, the Court adopts the stipulation of the parties in its entirety. IT IS HEREBY ORDERED that the status conference currently scheduled for Monday, January 30, 2012, be vacated and that the case be set for Monday, March 19, 2012, at 9:30 a.m. The Court finds that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. Accordingly, IT IS HEREBY ORDERED that, for the reasons stated in the parties' January 24, 2012, stipulation, the time within which the trial of this matter must be commenced under the Speedy Trial Act is excluded during the time period from the date of this stipulation, January 24, 2012, through and including March 19, 2012, pursuant to 18 U.S.C. §3161(h)(7)(A)&(B)(iv) [reasonable time to prepare] and Local Code T4.
____________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE