Filed: Feb. 11, 2015
Latest Update: Feb. 11, 2015
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE MORRISON C. ENGLAND, Jr., Chief District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas and defendant Antonia Reyna, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, February 12, 2015 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to March 26, 2015 at 9:00 a.m. in
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE MORRISON C. ENGLAND, Jr., Chief District Judge. STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas and defendant Antonia Reyna, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, February 12, 2015 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to March 26, 2015 at 9:00 a.m. in t..
More
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., Chief District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas and defendant Antonia Reyna, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, February 12, 2015 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to March 26, 2015 at 9:00 a.m. in the courtroom of the Honorable Morrison C. England, Jr.
The reason for this request is that additional time is needed to allow litigation of discovery issues. Ms. Radekin has prepared a discovery motion and it is ready for filing. The parties have agreed the motion will be set for hearing on March 18, 2015 at 2:00 p.m. to allow adequate time for the government to file an opposition and for the defense to file any reply. In addition, the defense is still actively engaged in investigation and other defense preparation. The court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until March 26, 2015 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED
Dated: February 6, 2014 BENJAMIN WAGNER
United States Attorney
/s/Jill Thomas
JILL THOMAS
Assistant United States Attorney
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of February 12, 2015 at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on March 26, 2015 at 9:00 a.m. The Court finds excludable time in this matter through March 26, 2015 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.
