Filed: Nov. 14, 2019
Latest Update: Nov. 14, 2019
Summary: Stipulation to Continue Preliminary Hearing (Fourth Request) CAM FERENBACH , Magistrate Judge . The parties jointly request that this Court vacate the preliminary hearing scheduled for November 15, 2019, and continue it for at least 90 days because: 1. The government intends on making an early production of discovery to the defendants in an effort to reach a pre-indictment plea agreement and lab test results remain outstanding. The government intends to disclose more discovery as it becom
Summary: Stipulation to Continue Preliminary Hearing (Fourth Request) CAM FERENBACH , Magistrate Judge . The parties jointly request that this Court vacate the preliminary hearing scheduled for November 15, 2019, and continue it for at least 90 days because: 1. The government intends on making an early production of discovery to the defendants in an effort to reach a pre-indictment plea agreement and lab test results remain outstanding. The government intends to disclose more discovery as it become..
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Stipulation to Continue Preliminary Hearing
(Fourth Request)
CAM FERENBACH, Magistrate Judge.
The parties jointly request that this Court vacate the preliminary hearing scheduled for November 15, 2019, and continue it for at least 90 days because:
1. The government intends on making an early production of discovery to the defendants in an effort to reach a pre-indictment plea agreement and lab test results remain outstanding. The government intends to disclose more discovery as it becomes available, and defense counsel will need time to review this discovery and discuss it with their clients.
2. A pre-indictment plea agreement would obviate the need for either a preliminary hearing or indictment by a grand jury.
3. Defendants are not incarcerated and do not object to a continuance.
4. Denial of this continuance would potentially prejudice the defendants and the government and would unnecessarily consume this Court's valuable resources.
5. Additionally, denial of this continuance could result in a miscarriage of justice. The additional time is excludable in computing the time within which the trial must commence under the Speedy Trial Act, 18 U.S.C. 3161(h)(7)(A), considering the factors under § 3161(h)(7)(B)(i), (iv).
This is the fourth request for continuance.
DATED: November 13, 2019.
Rene L. Valladares Nicholas A. Trutanich
Federal Public Defender United States Attorney
/s/ Erin Gettel /s/ Shaheen Torgoley
By_____________________________ By_____________________________
Erin Gettel Shaheen Torgoley
Assistant Federal Public Defender Assistant United States Attorney
/s/ Chris T. Rasmussen
By_____________________________
Chris T. Rasmussen
Counsel for Latoya Jones
Order Granting Fourth Stipulation to Continue Preliminary Hearing
Based on the Stipulation of counsel and good cause appearing, IT IS ORDERED that the preliminary hearing currently scheduled on November 15, 2019, at 4:00 p.m. is vacated and continued to February 13, 2020 at the hour of 4:00 p.m.