Free Terminate Deadlines and Hearings - District Court of California - California

Case 4:08-cr-00232-CW

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Filed 06/18/2008

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BARRY J. PORTMAN Federal Public Defender ANGELA M. HANSEN Assistant Federal Public Defender 555 - 12th Street, Suite 650 Oakland, CA 94607-3627 Telephone: (510) 637-3500 Counsel for Defendant BUGNATTO

IN THE UNITED STATES DISTRICT COURT 8 FOR THE NORTHERN DISTRICT OF CALIFORNIA 9 10 UNITED STATES OF AMERICA, 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 ) ) ) Plaintiff, ) vs. ) ) ) CASSANDRA DAWN BUGNATTO, ) Defendant. ) _____________________________________ ) No. CR-08-00232 CW STIPULATION AND ORDER CONTINUING STATUS HEARING AS MODIFIED Hearing Date: June 18, 2008 Requested Date: July 23, 2008

It is hereby stipulated between the parties that the status hearing date of June 18, 2008 should be continued to July 23, 2008 at 2:30 p.m. for a change of plea hearing. The parties further stipulate and agree that time should be excluded between June 18, 2008 until July 23, 2008 because counsel for Ms. Bugnatto needs additional time to review the discovery in this case and to research and calculate Ms. Bugnatto's sentencing guidelines. Ms. Bugnatto is currently in an inpatient drug treatment program and due to the demands of the program, she has little time to meet with counsel to review and discuss her case. As a result, counsel needs additional time to confer with her client regarding a plea disposition of this matter. The parties are actively negotiating a plea agreement and plan to have an agreement for the Court by the next hearing date. The parties agree that the ends of justice served by the continuance requested herein
Stip to Continue, 08-00032 CW

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Case 4:08-cr-00232-CW

Document 9

Filed 06/18/2008

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outweigh the best interest of the public and the defendant in a speedy trial because the failure to grant the continuance would deny counsel for the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Time should therefore be excluded pursuant to 18 U.S.C. §§ 3161(h)(8)(A) and (B)(iv). Dated: June 17, 2008 /s/ ANGELA M. HANSEN Assistant Federal Public Defender

Dated: June 17, 2008

/s/ DANIEL KALEBA Assistant United States Attorney

I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/S/) within this efiled document. /S/ ANGELA M. HANSEN

Stip to Continue, 08-00032 CW

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Case 4:08-cr-00232-CW

Document 9

Filed 06/18/2008

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Stip to Continue, 08-00032 CW

ORDER Based on the reasons provided in the stipulation of the parties above, the Court hereby finds that the ends of justice served by the continuance requested herein outweigh the best interest of the public and the defendant in a speedy trial because the failure to grant the continuance would deny counsel for the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court makes this finding because defense counsel needs additional time to review the discovery, to research the sentencing guidelines and to confer with the defendant and government counsel regarding a plea disposition. Based on these findings, IT IS HEREBY ORDERED that the status hearing date of June 18, 2008 is continued to July 23, 2008 at 2:30 p.m. for a change of plea hearing and that time is excluded from June 18, 2008 to July 23, 2008 pursuant to 18 U.S.C. §§3161 (h)(8)(A) and (B)(iv). If there is no disposition on July 23, counsel must be prepared to inform the Court of any motions to be filed, and a prompt briefing and hearing schedule will be set. If there is no disposition and no motions, a prompt trial date will be set. IT IS SO ORDERED. 6/18/08 HON. CLAUDIA WILKEN United States District Judge

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