Free Terminate Hearings - District Court of California - California

Case 4:08-cr-00232-CW

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Filed 05/12/2008

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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 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 It is hereby stipulated that the STATUS hearing date of May 14, 2008 be continued to June 18, 2008 at 2:00 p.m. In addition, the parties stipulate and agree that time should be excluded between May 14, 2008 until June 18, 2008 because the counsel for Ms. Bugnatto needs time to review the discovery in this case. This is a new case. Ms. Bugnatto was arraigned on April 18, 2008, and government counsel produced discovery last week. Because counsel for Ms. Bugnatto recently received the discovery in this identity theft case, she needs time to review these materials and to meet with Ms. Bugnatto. Additionally, last month counsel for Ms. Bugnatto began working in the Oakland office of the Federal Public Defender, and shortly after counsel began working in the office, over 20 cases were reassigned to her. Although counsel for Ms. Bugnatto picked up this case on a duty day, given the large and new caseload counsel was
Stip to Continue, 08-00032 CW

) ) ) Plaintiff, ) vs. ) ) ) CASSANDRA DAWN BUGNATTO, ) Defendant. ) _____________________________________ )

UNITED STATES OF AMERICA,

No. CR-08-00232 CW STIPULATION AND ORDER CONTINUING STATUS HEARING AS AMENDED Hearing Date: May 14, 2008 Requested Date: June 18, 2008

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Case 4:08-cr-00232-CW

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Filed 05/12/2008

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given when she began in the office, she needs more time to prepare her client's cases, including Ms. Bugnatto's. The parties agree 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. Time should therefore be excluded pursuant to 18 U.S.C. §§ 3161(h)(8)(A) and (B)(iv). May 12, 2008 Date /s/ ANGELA M. HANSEN Assistant Federal Public Defender

May 12, 2008 Date

/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 Counsel for Defendant

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 the 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 recently-produced discovery in this case. Based on these findings, IT IS HEREBY ORDERED THAT the STATUS hearing date of May 14, 2008 be continued to June 18, 2008 at 2:30 p.m. and that time be excluded from May
Stip to Continue, 08-00032 CW

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Case 4:08-cr-00232-CW

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Filed 05/12/2008

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14, 2008 to June 18, 2008 pursuant to 18 U.S.C. §§3161 (h)(8)(A) and (B)(iv). IT IS SO ORDERED. 5/12/08 Date HON. CLAUDIA WILKEN United States District Judge

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Stip to Continue, 08-00032 CW

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