Filed: Apr. 25, 2019
Latest Update: Apr. 25, 2019
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER DALE A. DROZD , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for a change of plea on April 29, 2019. 2. By this stipulation, defendant now moves to continue the status conference until May 13, 2019, and to exclude time between
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER DALE A. DROZD , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for a change of plea on April 29, 2019. 2. By this stipulation, defendant now moves to continue the status conference until May 13, 2019, and to exclude time between ..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER
DALE A. DROZD, District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for a change of plea on April 29, 2019.
2. By this stipulation, defendant now moves to continue the status conference until May 13, 2019, and to exclude time between April 29, 2019, and May 13, 2019, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the discovery associated with this case includes investigative reports and wiretap affidavits, related recordings, and additional documents. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b) Counsel for defendant desires additional time consult with her client regarding finalization of documents.
c) Counsel for defendant believes that failure to grant the above-requested continuance would deny him/her the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
d) The government does not object to the continuance.
e) Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.
f) 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 29, 2019 to May 13, 2019, 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'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.
IT IS SO STIPULATED.
Dated: April 25, 2019 MCGREGOR W. SCOTT
United States Attorney
/s/VINCENZA RABENN
VINCENZA RABENN
Assistant United States Attorney
Dated: April 25, 2019. /s/GALATEA DELAPP
GALATEA DELAPP
Counsel for Defendant
Michelle Madewell
ORDER
Good cause having been shown, the Change of Plea hearing currently set for April 29, 2019, at 10:00 a.m. is continued to May 13, 2019, at 10:00 a.m. Time shall be excluded by stipulation from the parties and pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv).
IT IS SO ORDERED.
