United Statesv.Brown

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISIONOct 3, 2011
No. 3-11-70238 MAG (N.D. Cal. Oct. 3, 2011)

No. 3-11-70238 MAG

10-03-2011

UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL DUPREE BROWN, Defendant.

MELINDA HAAG (CABN 132612) United States Attorney J. DOUGLAS WILSON (DCBN 412811) Deputy Chief, Criminal Division GARTH HIRE (CABN 187330) Assistant United States Attorney Attorneys for Plaintiff


MELINDA HAAG (CABN 132612)


United States Attorney


J. DOUGLAS WILSON (DCBN 412811)


Deputy Chief, Criminal Division


GARTH HIRE (CABN 187330)


Assistant United States Attorney


Attorneys for Plaintiff

STIPULATION TO CONTINUE AND

EXCLUDE TIME UNDER THE SPEEDY

TRIAL ACT; [PROPOSED] ORDER

Plaintiff, by and through its attorney of record, and defendant, by and through his attorney of record, hereby stipulate and ask the Court to find and order as follows:

1. Defendant is presently charged in a criminal complaint with violations of 21 U.S.C. §§ 841(a)(1), (b)(1)(C), 18 U.S.C. § 922(g)(1), and 18 U.S.C. § 924(c)(1)(A)(i). Defendant has previously waived his right to a preliminary hearing pursuant to Federal Rule of Criminal Procedure 5 and has previously waived the time to be charged by indictment or information on the charges contained in the criminal complaint until August 31, 2011.

2. Defendant again waives the time for the government to file an indictment or information against him on the charges contained in the criminal complaint under 18 U.S.C. § 3161(b) in order for the defendant and his counsel to further review the case materials and effectively prepare a defense to those charges and/or negotiate a pre-indictment resolution to this matter. For these reasons, the parties agree to exclude time under the Speedy Trial Act for defendant to be charged by indictment or information under 18 U.S.C. § 3161(b) from October 4, 2011, to October 26, 2011.

3. The parties further request that the matter be set for a status conference at 9:30 a.m. on October 26, 2011, before the Honorable Laurel Beeler, United States Magistrate Judge. IT IS SO STIPULATED.

Respectfully submitted,

MELINDA HAAG


United States Attorney


GARTH HIRE


Assistant United States Attorney


Attorneys for Plaintiff


UNITED STATES OF AMERICA


GARRICK LEW, ESQ.


Counsel for Michael Dupree Brown


[PROPOSED]
ORDER

FOR GOOD CAUSE SHOWN, IT IS SO FOUND AND ORDERED THAT:

The matter shall be scheduled for a status conference before this Court at 9:30 a.m. on October 26, 2011, and the time within which the defendant must be charged by indictment or information on the charges contained in the criminal complaint, pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(b), is hereby excluded from October 4, 2011, until October 26, 2011.

LAUREL BEELER


UNITED STATES MAGISTRATE JUDGE