USA v. Bonds

Filing 51

STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME by USA as to Barry Lamar Bonds (Finigan, Jeffrey) (Filed on 6/9/2008)

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1 2 3 4 5 6 7 8 9 10 11 JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney BRIAN J. STRETCH (CSBN 163973) Chief, Criminal Division MATTHEW A. PARRELLA (NYSBN 2040855) JEFFREY D. NEDROW (CASBN 161299) JEFFREY R. FINIGAN (CASBN 168285) Assistant United States Attorneys 450 Golden Gate Avenue San Francisco, California 94102 Telephone: (415) 436-7232 Facsimile: (415) 436-7234 Email: jeffrey.finigan@usdoj.gov Attorneys for Plaintiff UNITED STATES DISTRICT COURT 12 NORTHERN DISTRICT OF CALIFORNIA 13 SAN FRANCISCO DIVISION 14 15 UNITED STATES OF AMERICA, 16 Plaintiff, 17 18 19 BARRY LAMAR BONDS, 20 Defendant. 21 22 23 24 25 26 27 28 The above-captioned matter came before the Court on June 6, 2008, for initial appearance on the superseding indictment. The defendant was represented by Allen Ruby, Esq., and others, and the government was represented by Matthew Parrella, Assistant United States Attorney, and others. The matter was continued to March 2, 2009, at 9:00 a.m. in this Court for jury trial. The Court made a finding that the time from and including June 6, 2008, through March 2, 2009, should be excluded under the Speedy Trial Act, 18 U.S.C. 3161(h)(8)(A), because the STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME CR 07-0732 SI v. ) ) ) ) ) ) ) ) ) ) ) ) Criminal No. CR 07-0732 SI STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ends of justice served by taking such action outweighed the best interest of the public and the defendant in a speedy trial. The finding was based on the need for the defendant to have reasonable time necessary for effective preparation, taking into account the exercise of due diligence, pursuant to 18 U.S.C. 3161(h)(8)(B)(iv). The parties hereby agree to and request that the case be continued until March 2, 2009, and that the exclusion of time until then be granted. The parties agree and stipulate that the additional time is appropriate and necessary under Title 18, United States Code, 3161(h)(8)(A), because the ends of justice served by this continuance outweigh the best interest of the public and the defendant in a speedy trial. DATED: June 9, 2008 /s/ ALLEN RUBY Counsel for Barry L. Bonds DATED: June 9, 2008 /s/ JEFFREY FINIGAN Assistant U.S. Attorney So ordered. DATED: SUSAN ILLSTON UNITED STATES DISTRICT COURT JUDGE STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME CR 07-0732 SI 2

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