United Statesv.Dean

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIAApr 4, 2013
No.: CR 13-00212 PJH (N.D. Cal. Apr. 4, 2013)

No.: CR 13-00212 PJH

04-04-2013

UNITED STATES OF AMERICA, Plaintiff, v. REGINA DEAN, Defendants.

Brian Lewis Assistant United States Attorney Nicole Giacinti Counsel for Regina Dean


Nicole Giacinti (SBN 233121)
Morris & Giacinti LLP
899 Ellis Street
San Francisco, CA 94109
Tel: (415) 553-3902
Fax: (415) 848-9130
Counsel for Defendant, Regina Dean

STIPULATION AND [PROPOSED]

ORDER CONTINUING HEARING AND

EXCLUDING TIME


Court: Judge Kandis Westmore

On March 27, 2013, the Court held a detention hearing in this case and set April 4, 2013, is the date for preliminary hearing or arraignment. On March 28, 2013, the government filed an ndictment against the above named defendant. Counsel for defendant has a previously scheduled onflicting court appearance on the date currently scheduled for arraignment. The next available date for both defense counsel and the government is April 9, 2013. The parties hereby stipulate nd request to set the date for arraignment on the recently filed indictment for April 9, 2013.

Pursuant to 18 U.S.C. § 3161, the defendant and the government consent to the extension of time and the parties represent that good cause exists for this extension, including continuity of counsel. See 1 U.S.C. § 3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such an extension of time outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

It is so stipulated.

________________________


Brian Lewis


Assistant United States Attorney


________________________


Nicole Giacinti


Counsel for Regina Dean


[PROPOSED] ORDER

For the reasons stated above, the Court sets April 9, 2013, as the date for arraignment. The Court also finds that exclusion of time from April 4, 2013, to April 9, 2013, from the time limits applicable under 18 U.S.C. § 3161 is warranted; that the ends ofjustice served by the continuance outweigh the interests of the public and the defendant in the prompt disposition of this criminal case; and that the failure to grant the requested exclusion of time would deny counsel for the defendant continuity of counsel and would result in a miscarriage of justice. 18 U.S.C. § 3161(h)(7)(B)(iv).

It is so ordered.

________________________


The Honorable Kandis Westmore


United States Magistrate Judge