John A. Mendez
BRUCE LOCKE (#177787)
Moss & Locke
Attorneys for
TODD ALLEN SMITH
STIPULATION TO CONTINUE STATUS
CONFERENCE AND EXCLUDE TIME
UNDER SPEEDY TRIAL ACT
IT IS HEREBY STIPULATED AND AGREED between the defendants, Damn Johnston, Todd Smith, and Cheryl Peterson, by and through their undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Todd Pickles, that the status conference presently set for September 6, 2011 at 9:30 a.m., should be continued to October 4, 2011 at 9:30 a.m., and that time under the Speedy Trial Act should be excluded from September 6, 2011 through October 4, 2011.
The reason for the continuance is that the defendants are continuing their investigation and preparation of the matter for trial. There is substantial discovery and the issues are complicated. Accordingly, the time between September 6, 2011 and October 4, 2011 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Pickles and the undersigned defense counsel have authorized Mr. Locke to sign this pleading for them.
BRUCE LOCKE
Attorney for Todd Smith
For PATRICK HANLEY
Attorney for Darrin Johnston
For DOUGLAS BEEVERS
Attorney for Cheryl Peterson
For TODD PICKLES
Attorney for the United States
The Court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial.
IT IS SO ORDERED.
John A. Mendez
UNITED STATES DISTRICT JUDGE