Filed: Aug. 02, 2017
Latest Update: Aug. 02, 2017
Summary: STIPULATION AND [PROPOSED] ORDER RESETTING FIRST APPEARANCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT EDWARD M. CHEN , District Judge . STIPULATION IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that: 1. The parties were scheduled to appear before the Court on August 2, 2017 at 2:30 p.m. for a first appearance. On August 2, 2017, prior to 2:30 p.m., Assistant United States Attorney Karen Kreuzkamp, counsel for the Government, and Erik Levin, counsel for defend
Summary: STIPULATION AND [PROPOSED] ORDER RESETTING FIRST APPEARANCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT EDWARD M. CHEN , District Judge . STIPULATION IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that: 1. The parties were scheduled to appear before the Court on August 2, 2017 at 2:30 p.m. for a first appearance. On August 2, 2017, prior to 2:30 p.m., Assistant United States Attorney Karen Kreuzkamp, counsel for the Government, and Erik Levin, counsel for defenda..
More
STIPULATION AND [PROPOSED] ORDER RESETTING FIRST APPEARANCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
EDWARD M. CHEN, District Judge.
STIPULATION
IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that:
1. The parties were scheduled to appear before the Court on August 2, 2017 at 2:30 p.m. for a first appearance. On August 2, 2017, prior to 2:30 p.m., Assistant United States Attorney Karen Kreuzkamp, counsel for the Government, and Erik Levin, counsel for defendant Ronald Glenn Jones, learned that Mr. Jones, who is in custody, was not medically cleared for transport by the United States Marshal Service to the Court. The parties therefore request that the first appearance by reset for September 27, 2017 at 2:30 p.m.
2. The parties respectfully submit and agree that the period from August 2, 2017 through and including September 27, 2017 should be excluded from the otherwise applicable Speedy Trial Act computation because the continuance is necessary for continuity of defense counsel and effective preparation of counsel, taking into account the exercise of due diligence. Specifically, the time requested for exclusion will allow for continuity of counsel for the defendant, as his counsel is scheduled to travel for part of August, and will allow defense counsel time to review the discovery.
IT IS SO STIPULATED.
[PROPOSED] ORDER
Based upon the above-described Stipulation, THE COURT FINDS THAT the ends of justice served by granting a continuance August 2, 2017 through and including September 27, 2017 outweigh the best interest of the public and the defendant in a speedy trial, and that failure to grant such a continuance would unreasonably deny the defendant continuity of counsel and would deny defense counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and would result in a miscarriage of justice. See 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).
Accordingly, THE COURT ORDERS THAT:
1. The parties shall appear before the Court on September 27, 2017 at 2:30 p.m. for a status conference.
2. The period from August 2, 2017 through and including September 27, 2017 is excluded from the otherwise applicable Speedy Trial Act computation, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(iv).
IT IS SO ORDERED.
