Benjamin v. Google Inc.

Filing 11

STIPULATION EXTENDING TIME TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT by Google Inc.. (Attachments: # 1 Signature Page (Declarations/Stipulations))(Gratz, Joseph) (Filed on 12/2/2009)

Benjamin v. Google Inc.

Doc. 11

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K E V IN V. RYAN (CSBN 118321) U n ite d States Attorney E U M I L. CHOI (WVBN 0722) A c tin g Chief, Criminal Division P H IL IP J. KEARNEY (CSBN 114978) R IC H A R D J. CUTLER (CSBN 146180) A s s is ta n t United States Attorney 4 5 0 Golden Gate Avenue S a n Francisco, California 94102 T e le p h o n e : [phone] A tto rn e ys for Plaintiff U N I T E D STATES DISTRICT COURT N O R T H E R N DISTRICT OF CALIFORNIA S A N FRANCISCO DIVISION U N IT E D STATES OF AMERICA, P l a in tif f , ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) C rim in a l No. CR 05-00167 WHA

v.

S T IP U L A T I O N AND [PROPOSED] O R D E R EXCLUDING TIME

R O N N IE CALLOWAY, a /k /a "Oreo," D e f e n d a n t.

T h e above-captioned matter came before the Court on December 20, 2005, for s ta tu s . The defendant, RONNIE CALLOWAY, who was present and was represented by S u s a n Raffanti, Esq., and the government was represented by Richard J. Cutler, Assistant U n i te d States Attorney. The case was then continued to join the co-defendants' case c u rre n tly set for status on March 29, 2006, at 2:00 p.m. The Court made a finding on the re c o rd that the time between December 20, 2005, and March 29, 2006 should be excluded u n d e r the Speedy Trial Act, 18 U.S.C. § 3161(h)(3)(B)(8) and Federal Rule of STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME C R 05-00167 WHA
Dockets.Justia.com

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C rim in a l Procedure 5.1, because the ends of justice served by taking such action o u tw e ig h e d the best interest of the public and the defendant in a speedy trial. That f in d in g was based on the complexity of the case, the defendant's request for additional tim e to review an extensive amount of discovery material provided by the government, as w e ll as time to insure the effective preparation of her counsel. Counsel for the defendant in d ic a te d a need for additional time to adequately prepare the matter, taking into account th e exercise of due diligence. That finding was made pursuant to 18 U.S.C. §§ 3 1 6 1 (h )( 8 )( A ) and (B)(ii). T h e parties hereby agree to and request that the case be continued until March 29, 2 0 0 6 at 2:00 p.m. and that an exclusion of time until that date be granted. The parties a g re e and stipulate that the additional time is appropriate and necessary under Title 18, U n ite d States Code, Sections 3161(h)(8)(A) and (B)(ii), because the ends of justice s e rv e d by this continuance outweigh the best interest of the public and the defendant in a s p e e d y trial.

D A T E D : 12/20/05

/S/ S U S A N RAFFANTI, ESQ., C o u n s e l for DEFENDANT R O N N IE CALLOWAY

D A T E D : 12/20/05

/S/ R IC H A R D J. CUTLER A s s is ta n t United States Attorney

24 25 26 27 28 STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME C R 05-00167 WHA D A T E D : December 22, 2005

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