Free Stipulation - District Court of California - California

Case 4:07-cr-00599-SBA

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Filed 09/12/2008

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JOSEPH P. RUSSONIELLO (CABN 44332) United States Attorney BRIAN J. STRETCH (CABN 163973) Chief, Criminal Division CHRISTINE Y. WONG (NYBN 3988607) Assistant United States Attorney 1301 Clay Street, Suite 340-S Oakland, California 94612 Telephone: (510) 637-3717 Facsimile: (510) 637-3724 E-Mail: [email protected]

Attorneys for Plaintiff 10 UNITED STATES DISTRICT COURT 11 NORTHERN DISTRICT OF CALIFORNIA 12 OAKLAND DIVISION 13 UNITED STATES OF AMERICA, 14 Plaintiff, 15 v. 16 DARREN BROWN, 17 Defendant. 18 19 20 21 22 23 24 25 26 27 28 The parties jointly request that this Court vacate the status hearing set for September 16, 2008, set a new status hearing in this matter on October 7, 2008 at 9:00 a.m., and exclude time under the Speedy Trial Act between September 16, 2008 and October 7, 2008. On September 2, 2008, at the status hearing in the above-captioned matter, the Court set the next status hearing for September 16, 2008, as defense counsel requested certain discovery from the Government. The Court also excluded time, pursuant to the Speedy Trial Act, between September 2, 2008 and September 16, 2008 to allow for the effective preparation of counsel, as defense counsel needed time to review the additional discovery. The Government has since produced additional discovery to defense counsel, but defense counsel needs additional time to
JOINT MOTION TO SET STATUS HEARING ON OCTOBER 7, 2008 AND TO EXCLUDE TIM E No. CR-07-0599 SBA

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No. CR-07-0599 SBA JOINT MOTION TO SET STATUS HEARING DATE ON OCTOBER 7, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: October 7, 2008 9:00 a.m. Hon. Saundra B. Armstrong

Case 4:07-cr-00599-SBA

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review the discovery, discuss the discovery with the defendant, and determine whether there are any motions to file. The parties hereby jointly request that the Court vacate the status hearing set for September 16, 2008 and reschedule the status hearing for October 7, 2008. The parties further jointly request that the Court exclude time between September 16, 2008 and October 7, 2008 under the Speedy Trial Act for the reasons stated above and pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv). The parties agree the ends of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial.

DATED: September 12, 2008

___________/s/___________________ CHRISTINE Y. WONG Assistant United States Attorney Counsel for United States

______/s/________________________ JOYCE LEAVITT Counsel for Darren Brown

JOINT MOTION TO SET STATUS HEARING ON OCTOBER 7, 2008 AND TO EXCLUDE TIM E No. CR-07-0599 SBA

Case 4:07-cr-00599-SBA

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 The parties jointly requested that a status hearing in this matter be set on October 7, 2008, and that time continue to be excluded under the Speedy Trial Act between September 16, 2008 and October 7, 2008 to allow for the effective preparation of counsel for the reasons set forth in the parties' joint request. For these stated reasons, the Court finds that the ends of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. Good cause appearing therefor, and pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv), IT IS HEREBY ORDERED that the status hearing in this matter is set for October 7, 2008 at 9:00 a.m., and that time between September 16, 2008 and October 7, 2008 is excluded //// ////
JOINT MOTION TO SET STATUS HEARING ON OCTOBER 7, 2008 AND TO EXCLUDE TIM E No. CR-07-0599 SBA

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION UNITED STATES OF AMERICA, Plaintiff, v. DARREN BROWN, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) No. CR-07-599 SBA [PROPOSED] ORDER GRANTING JOINT MOTION TO SET STATUS HEARING DATE ON OCTOBER 7, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: October 7, 2008 9:00 a.m. Hon. Saundra B. Armstrong

Case 4:07-cr-00599-SBA

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under the Speedy Trial Act to allow for the effective preparation of counsel, taking into account the exercise of due diligence.

DATED:_________________

____________________________________ HON. SAUNDRA BROWN ARMSTRONG United States District Judge

JOINT MOTION TO SET STATUS HEARING ON OCTOBER 7, 2008 AND TO EXCLUDE TIM E No. CR-07-0599 SBA