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U.S. v. Carpenter, 2:14-CR-00309-GEB. (2016)

Court: District Court, E.D. California Number: infdco20160408l13 Visitors: 18
Filed: Apr. 07, 2016
Latest Update: Apr. 07, 2016
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER THE SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER GARLAND E. BURRELL, Jr. , Senior District Judge . Plaintiff United States of America, by and through Assistant United States Attorney Todd A. Pickles, and defendant Carissa J. Carpenter, by and through counsel Scott L. Tedmon, hereby agree and stipulate as follows: 1. This matter is currently set for status conference on April 8, 2016 at 9:00 a.m. 2. By this stipulation, the parties now
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER THE SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

Plaintiff United States of America, by and through Assistant United States Attorney Todd A. Pickles, and defendant Carissa J. Carpenter, by and through counsel Scott L. Tedmon, hereby agree and stipulate as follows:

1. This matter is currently set for status conference on April 8, 2016 at 9:00 a.m. 2. By this stipulation, the parties now move to continue the status conference to Friday, July 29, 2016 at 9:00 a.m., and to exclude time between April 8, 2016 and July 29, 2016 under Local Code T4. 3. The parties agree and stipulate, and request the Court find the following: a) On January 22, 2016, the Court ordered that Scott L. Tedmon be substituted in as counsel of record for defendant Carissa J. Carpenter, replacing former counsel of record Benjamin D. Galloway. b) Mr. Tedmon needs additional time to continue to review and analyze the voluminous discovery, meet and confer with Ms. Carpenter, identify and develop investigative needs, and prepare her defense. Additionally, Mr. Tedmon needs additional time to meet and confer with the government regarding the ongoing status of the case. c) Mr. Tedmon believes the failure to grant the above-requested continuance would deny him reasonable time necessary for effective preparation, taking into account the exercise of due diligence. d) Based on the foregoing, the ends of justice served by continuing the case regarding defendant Carissa J. Carpenter as requested outweigh the best interest of the public and defendant Carissa J. Carpenter in a speedy trial within the original date prescribed by the Speedy Trial Act. e) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of April 8, 2016 to July 29, 2016, 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 granted by the Court at defendant Carissa J. Carpenter'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 defendant Carissa J. Carpenter 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.

IT IS SO STIPULATED.

DATED: April 5, 2016 BENJAMIN B. WAGNER United States Attorney /s/ Todd A. Pickles TODD A. PICKLES Assistant United States Attorney

FINDINGS AND ORDER

IT IS SO FOUND AND ORDERED.

Source:  Leagle

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