Filed: Mar. 07, 2018
Latest Update: Mar. 07, 2018
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA OR TRIAL SETTING HEARING JON S. TIGAR , District Judge . Defendant RYAN JAY ROSENTHAL, by and through his counsel undersigned and the United States of America, through Assistant United States Attorney MEREDITH OSBORN, hereby stipulate and respectfully request that the Court vacate the Change of Plea or Trial Setting Hearing in the above-captioned case, currently set for Friday, March 9, 2018, at 09:30 a.m., and reset it to a Chang
Summary: STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA OR TRIAL SETTING HEARING JON S. TIGAR , District Judge . Defendant RYAN JAY ROSENTHAL, by and through his counsel undersigned and the United States of America, through Assistant United States Attorney MEREDITH OSBORN, hereby stipulate and respectfully request that the Court vacate the Change of Plea or Trial Setting Hearing in the above-captioned case, currently set for Friday, March 9, 2018, at 09:30 a.m., and reset it to a Change..
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STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA OR TRIAL SETTING HEARING
JON S. TIGAR, District Judge.
Defendant RYAN JAY ROSENTHAL, by and through his counsel undersigned and the United States of America, through Assistant United States Attorney MEREDITH OSBORN, hereby stipulate and respectfully request that the Court vacate the Change of Plea or Trial Setting Hearing in the above-captioned case, currently set for Friday, March 9, 2018, at 09:30 a.m., and reset it to a Change of Plea hearing on Friday, March 23, 2018, at 09:30 a.m.
This is the parties' first request to continue the Change of Plea or Trial Setting Hearing as to Defendant Rosenthal. The parties last appeared before the Court on January 05, 2018 for status.
Discovery from the Government is complete, and the parties are close to reaching a resolution in this case. Continuing the Change of Plea hearing, as requested, would allow the parties sufficient time to finalize the plea agreement and would allow Defense Counsel reasonable time to review the plea offer with the Defendant.
This request is also made because Defense Counsel had a minor medical procedure done on Friday, March 02, 2018, and requires additional time to rehabilitate.
Based on the above, the parties further stipulate and agree that the time between Friday, March 09, 2018 and Friday, March 23, 2018, should be excluded from computation of the time for commencement of trial under the Speedy Trial Act and that the ends of justice are served by the Court excluding such time in order to allow defense counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and continuity of counsel. 18 U.S.C. § 3161 (h) (7) (A) and (B) (iv).
For these reasons, the Defendant, defense counsel, and the government stipulate and agree that the interests of justice are served by vacating the Change of Plea or Trial Setting Hearing currently set for Friday, March 09, 2019 at 09:30 a.m. and resetting it for a Change of Plea hearing on Friday, March 23, 2018, at 09:30 a.m. outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161 (h) (7) (B) (iv); 18 U.S.C. § 3161 (h) (7) (B) (ii).
IT IS SO STIPULATED.
IT IS SO ORDERED.
