Opinion
No. Cr. S. 07-00020-GEB, Cr. S. 01-00417-GEB.
August 14, 2007
DANIEL J. BRODERICK, #89424, Acting Federal Defender, RACHELLE BARBOUR, Bar #185395, Assistant Federal Defender, Designated Counsel for Service, Sacramento, California, Attorney for Defendant RON SEAN ARTER.
McGREGOR SCOTT, United States Attorney.
CAMIL SKIPPER, Assistant U.S. Attorney, Attorney for Plaintiff.
STIPULATION AND PROPOSED ORDER TO CONTINUE MOTIONS BRIEFING SCHEDULE AND NON-EVIDENTIARY HEARING; [proposed] ORDER
It is hereby stipulated and agreed to between the United States of America through CAMIL SKIPPER, Assistant U.S. Attorney, and defendant, RON ARTER, by and though his counsel, RACHELLE BARBOUR, Assistant Federal Defender that the non-evidentiary hearing previously set for September 28, 2007 in both above-numbered cases be continued to November 2, 2007, and that time continue to be excluded for preparation of defense counsel in Cr. S. 07-0020-GEB until the filing of motions.
This continuance is being requested because defense counsel needs additional time to prepare motions and investigate the case. The parties propose the following motions briefing schedule:
Defense motions due September 21, 2007
Government opposition due October 19, 2007
Defense reply due October 26, 2007
Non-Evidentiary Hearing on November 2, 2007
For this reason, the parties agree 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 and that time under the Speedy Trial Act in case number Cr. S. 07-0020-GEB may be excluded from the date of this order through the date motions are filed pursuant to 18 U.S.C. § 3161(h)(8)(iv) (Local Code T4), and thereafter for the pendency of motions pursuant to 18 U.S.C. § 3161(h)(1)(F) (Local Code E).