U.S. v. KNOCKUM, 14-CR-0115-JAM. (2015)
Court: District Court, E.D. California
Number: infdco20150120910
Visitors: 17
Filed: Jan. 16, 2015
Latest Update: Jan. 16, 2015
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE; FINDING OF EXCLUDABLE TIME JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, through Assistant U.S. Attorney Sherry D. Haus and defendant, Kenneth Knockum, through his attorney, Christopher Haydn-Myer, hereby stipulate and agree as follows: 1. A status conference is currently set for January 20, 2015 at 9:30 a.m. 2. By this stipulation, the above-named defendant now moves to continue the status con
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE; FINDING OF EXCLUDABLE TIME JOHN A. MENDEZ, District Judge. STIPULATION Plaintiff, United States of America, through Assistant U.S. Attorney Sherry D. Haus and defendant, Kenneth Knockum, through his attorney, Christopher Haydn-Myer, hereby stipulate and agree as follows: 1. A status conference is currently set for January 20, 2015 at 9:30 a.m. 2. By this stipulation, the above-named defendant now moves to continue the status conf..
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STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE; FINDING OF EXCLUDABLE TIME
JOHN A. MENDEZ, District Judge.
STIPULATION
Plaintiff, United States of America, through Assistant U.S. Attorney Sherry D. Haus and defendant, Kenneth Knockum, through his attorney, Christopher Haydn-Myer, hereby stipulate and agree as follows:
1. A status conference is currently set for January 20, 2015 at 9:30 a.m.
2. By this stipulation, the above-named defendant now moves to continue the status conference to March 10, 2015 at 9:30 a.m., and to exclude time between January 20, 2015 to March 10, 2015 under Local Code T4. Plaintiff does not oppose this request.
3. The basis upon which the parties agree to this proposed continuance of the status conference is as follows:
a. The government has produced discovery which to date includes over 200 pages containing investigative materials. Counsel for Mr. Knockum was appointed to represent Mr. Knockum on August 20, 2014. Counsel has requested that additional documents be provided through the discovery process from the United States government, and counsel needs additional time to read the discovery, research relevant case law, meet with Mr. Knockum, and conduct investigation.
b. Counsel for the defendant believes that failure to grant the above-requested continuance would deny his client the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
c. Plaintiff does not object to the continuance.
d. Based on the above-stated findings, the ends of justice served by continuing the status conference as requested outweigh the best interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.
e. For the purpose of computing time under the Speedy Trial Act, 16 U.S.C. § 3161, et seq., within which trial must commence, the time period from January 20, 2015 to March 10, 2015 inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(a), B (iv) [Local Code T4] because it results from a continuance by the Court at the defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.
5. Finally, Christopher Haydn-Myer has been authorized by counsel to sign this stipulation on her behalf.
IT IS SO STIPULATED.
ORDER
IT IS SO FOUND AND ORDERED.
Source: Leagle
