Filed: Jun. 17, 2019
Latest Update: Jun. 17, 2019
Summary: JOINT REQUEST AND STIPULATION RE: SETTING DATE FOR ENTRY OF OPEN PLEA; [PROPOSED] ORDER JAMES DONATO , District Judge . This matter is currently set for a status conference and trial setting on June 19, 2019, at 10:30 a.m. The parties have discussed the matter and potential resolution at length and Dominic Desmond Cullen has decided to plead guilty to the Indictment to the Court without the benefit of a plea agreement. Defense counsel for Mr. Cullen will be out of the State of California o
Summary: JOINT REQUEST AND STIPULATION RE: SETTING DATE FOR ENTRY OF OPEN PLEA; [PROPOSED] ORDER JAMES DONATO , District Judge . This matter is currently set for a status conference and trial setting on June 19, 2019, at 10:30 a.m. The parties have discussed the matter and potential resolution at length and Dominic Desmond Cullen has decided to plead guilty to the Indictment to the Court without the benefit of a plea agreement. Defense counsel for Mr. Cullen will be out of the State of California on..
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JOINT REQUEST AND STIPULATION RE: SETTING DATE FOR ENTRY OF OPEN PLEA; [PROPOSED] ORDER
JAMES DONATO, District Judge.
This matter is currently set for a status conference and trial setting on June 19, 2019, at 10:30 a.m. The parties have discussed the matter and potential resolution at length and Dominic Desmond Cullen has decided to plead guilty to the Indictment to the Court without the benefit of a plea agreement.
Defense counsel for Mr. Cullen will be out of the State of California on June 19, 2019, and requests that this matter go over to July 10, 2019, for Mr. Cullen's change of plea. As such, Mr. Cullen requests and the parties jointly stipulate that this matter go over to July 10, 2019, at 10:30 a.m., for the entry of an open plea. Mr. Cullen's counsel is needed to prepare Mr. Cullen for his change of plea and to further prepare himself for the change of plea.
The parties further agree and stipulate that the time between June 19, 2019, through and including July 10, 2019, may be time excluded from the Speedy Trial Act, in order to ensure the reasonable time necessary for the continuity of counsel and the effective preparation of counsel, pursuant to Title 18, United States Code Sections 3161(b), (h)(7)(A), (h)(7)(B)(iv). The parties agree that the ends of justice served by excluding the above period of time outweigh the best interest of the public and the defendant in speedy trial.
SO STIPULATED.
DAVID ANDERSON
United States Attorney
Dated: June 17, 2019 THOMAS R. GREEN
Assistant United States Attorney
Dated: June 17, 2019 EDWIN K. PRATHER
Attorney for Defendant
DOMINIC DESMOND CULLEN
[PROPOSED] ORDER
GOOD CAUSE APPEARING and per the parties' stipulation, IT IS HEREBY ORDERED that the June 19, 2019 status conference be vacated and this matter be set for the entry of an open plea on July 10, 2019, at 10:30 a.m.
The time from June 19, 2019, through and including July 10, 2019, shall be time excluded from Speedy Trial Act calculations, in order to ensure the reasonable time necessary for the continunity of counsel and for the effective preparation and continunity of counsel, pursuant to Title 18, United States Code §§ 3161(b), (h)(7)(A), (h)(7)(B)(iv). The Court finds that the ends of justice served by excluding the above period of time outweigh the best interest of the public and the defendant in speedy trial.
