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U.S. v. CLARK, 4:15-CR-581-JST. (2016)

Court: District Court, N.D. California Number: infdco20160115h26 Visitors: 14
Filed: Jan. 12, 2016
Latest Update: Jan. 12, 2016
Summary: STIPULATION AND [PROPOSED] ORDER CHANGING DATE FOR STATUS CONFERENCE AND EXCLUDING TIME JON S. TIGAR , District Judge . This matter is currently set for the initial status conference on January 22, 2016. The Indictment charges the defendant with using her position as a Transportation Security Officer for the Transportation Security Administration ("TSA") at the Oakland International Airport ("OAK Airport") in conspiracies to obstruct TSA's security functions in the screening of carry-
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STIPULATION AND [PROPOSED] ORDER CHANGING DATE FOR STATUS CONFERENCE AND EXCLUDING TIME

This matter is currently set for the initial status conference on January 22, 2016. The Indictment charges the defendant with using her position as a Transportation Security Officer for the Transportation Security Administration ("TSA") at the Oakland International Airport ("OAK Airport") in conspiracies to obstruct TSA's security functions in the screening of carry-on baggage and to smuggle controlled substances into and through the OAK Airport for delivery throughout the United States. The defendant made her initial appearance on December 17, 2015, and was released on bond December 18, 2015.

The parties respectfully request that the initial status conference be moved to March 18, 2016. The United States has thus far produced more than 3,900 pages of discovery. Additionally, the parties have agreed to a protective order for a subset of the discovery, conferred to discuss how discovery is ongoing, and conferred to determine whether a pre-trial resolution is possible. The parties stipulate that additional time is needed for ongoing discovery, effective preparation, and conferring to determine whether a pre-trial resolution is possible. Therefore, the parties respectfully request the resetting of initial status conference to March 18, 2016.

The parties also request that time be excluded under the Speedy Trial Act between January 22, 2016, the date of the originally scheduled initial status conference, and March 18, 2016, as the ends of justice from such an exclusion outweigh the best interest of the public and the defendant in a speedy trial because such an exclusion provides defense counsel reasonable time for effective preparation, taking into account due diligence, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (h)(7)(B)(iv).

IT IS SO STIPULATED.

[PROPOSED] ORDER CHANGING DATE FOR STATUS CONFERENCE AND EXCLUDING TIME

Based on the stipulation of the parties and on good cause shown, the Court orders that:

(1) the initial status conference, currently scheduled on January 22, 2016, is hereby moved to March 18, 2016; and (2) time is hereby excluded under the Speedy Trial Act between January 22, 2016, the date of the originally scheduled initial status conference, and March 18, 2016, as the ends of justice from such an exclusion outweigh the best interest of the public and the defendant in a speedy trial because such an exclusion provides defense counsel reasonable time for effective preparation, taking into account due diligence, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (h)(7)(B)(iv).

IT IS SO ORDERED.

Source:  Leagle

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