Opinion
No. CR. S-09-179 GEB
01-20-2012
UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY VASSALLO, Defendant.
BRUCE LOCKE (#177787) Moss & Locke Attorneys for ANTHONY VASSALLO
BRUCE LOCKE (#177787)
Moss & Locke
Attorneys for
ANTHONY VASSALLO
STIPULATION AND PROPOSED
ORDER TO CONTINUE THE
STATUS CONFERENCE FROM
JANUARY 20, 2012 TO FEBRUARY
3, 2012 AT 9:00 A.M.
IT IS HEREBY STIPULATED AND AGREED between the defendant, Anthony Vassallo, by and through his defense counsel, Bruce Locke, and the United States of America by and through its counsel, Assistant U.S. Attorney Jean Hobler, that the status conference originally scheduled for January 20, 2012 should be continued to February 3, 2012 at 9:00 a.m..
The reason for the continuance is that the Court was unavailable for the status conference originally scheduled for January 20, 2012 and, additionally, the parties are in the process of negotiating to resolve the case without a trial and the defense needs additional time to present additional information to the government and to consider the government's offer. Accordingly, the time between January 20, 2012 and February 3, 2012 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Ms. Hobler has authorized Mr. Locke to sign this pleading for her.
Respectfully submitted,
_________________________
BRUCE LOCKE
Attorney for Anthony Vassallo
Bruce Locke
For JEAN HOBLER
Attorney for the United States
The Court finds, based upon the parties' stipulation, that the ends of justice served by granting this continuance outweigh the interests of the defendant and the public in a speedy trial, and
IT IS SO ORDERED.
_________________________
GARLAND E. BURRELL, JR.
United States District Judge