DALE A. DROZD
DANIEL J. BRODERICK, #89424
Federal Defender
LINDA C. HARTER, Bar #179741
Chief Assistant Federal Defender
Designated Counsel for Service
Attorney for Defendant
KIANI GARCIA
STIPULATION AND [PROPOSED] ORDER
CONTINUING STATUS CONFERENCE
Date: October 23, 2012
Judge: Hon. Dale A. Drozd
IT IS HEREBY STIPULATED between the parties through their respective counsel, Chris Chang, Assistant United States Attorney, and Linda C. Harter, Chief Assistant Federal Defender, attorney for KIANI GARCIA, that the Court vacate the status conference on October 2, 2012 at 10:00 a.m. and set a new status conference on October 23, 2012 at 10:00 a.m.
The parties also agree that the ends of justice served by granting defendant's request for a continuance, outweigh the best interest of the public and the defendant in a speedy trial, because the defense requires more time to investigate and negotiate a resolution. The parties expect a deferred prosecution agreement will be signed soon.
The parties stipulate that for the purpose of computing time under the Speedy Trial Act, the Court should exclude time from the date of this order through October 23, 2012, for defense preparation and investigation. 18 U.S.C. § 3161(h)(7)(A) and (B) (iv) [Local Code T4].
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
___________________
LINDA C. HARTER
Chief Assistant Federal Defender
Attorney for Defendant
KIANI GARCIA
BENJAMIN B. WAGNER
United States Attorney
_____________
CHRIS CHANG
Assistant United States Attorney
ORDER
IT IS SO ORDERED.
____________________
DALE A. DROZD
United States Magistrate Judge