Opinion
No. 1:10-cr-00090 AWI
09-14-2011
UNITED STATES OF AMERICA, Plaintiff, v. STEPHANIE YOST, Defendant.
DANIEL J. BRODERICK, Bar #89424 Federal Defender FRANCINE ZEPEDA, Bar #91175 Assistant Federal Defender CHARLES J. LEE, Bar #221057 Assistant Federal Defender Designated Counsel for Service Attorneys for Defendant STEPHANIE YOST
DANIEL J. BRODERICK, Bar #89424
Federal Defender
FRANCINE ZEPEDA, Bar #91175
Assistant Federal Defender
CHARLES J. LEE, Bar #221057
Assistant Federal Defender
Designated Counsel for Service
Attorneys for Defendant
STEPHANIE YOST
STIPULATION AND ORDER TO CONTINUE JURY TRIAL
JUDGE: Hon. Anthony W. Ishii
IT IS HEREBY STIPULATED by and between the parties hereto, through their respective counsel, that the jury trial in the above-captioned matter now set for October 18, 2011, may be continued to January 24, 2012 at 8:30 a.m. Trial confirmation now set for October 3, 2011, may be continued to January 9, 2012. The parties also agree that the deadline for defendant Yost to accept the plea offer of the government is extended until December 20, 2011, at 5:00 p.m. A signed plea would need to be submitted to the government by that date and time.
This continuance is at the request of counsel for defendant. Counsel needs further time for proper preparation of the case for trial. Counsel has experienced delays in the preparation of the case. First, the defendant continues to suffer significant medical setbacks. These setbacks affect her ability to participate in the preparation of her defense. Counsel has obtained voluminous bank records in this case and needs additional time to review them, to consult with an expert in employment, as well as complete other ongoing investigation.
Ms. Yost's medical condition has previously been discussed and counsel is willing to discuss additional details with the Court and the government if requested.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
BENJAMIN B. WAGNER
United States Attorney
MARK J. MCKEON
Assistant United States Attorney
Attorney for Plaintiff
DANIEL J. BRODERICK
Federal Defender
FRANCINE ZEPEDA
Assistant Federal Defender
Attorneys for Defendant
STEPHANIE YOST
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv). IT IS SO ORDERED.
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CHIEF UNITED STATES DISTRICT JUDGE
Yost - Stipulation and Order
to Continue Jury Trial