v. Google, Inc.

Filing 45

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v. Google, Inc. Doc. 45 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 March 21, 2008. 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 June 6, 2008, at 11:00 a.m. in this Court for status. The Court made a finding that the time from and including March 21, 2008, through June 6, 2008, 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 Dockets.Justia.com 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, and for continuity of counsel pursuant to 18 U.S.C. 3161(h)(8)(B)(iv). The finding was also based upon the government's representation that it intends to seek a superseding indictment prior to June 6, 2008, and its request for a sufficient amount of time to accomplish that. The parties hereby agree to and request that the case be continued until June 6, 2008, 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. This time exclusion will allow defense counsel to effectively prepare, taking into account the exercise of due diligence, and will provide for continuity of counsel for the defendant. This time exclusion will also allow government counsel time to seek a superseding indictment. DATED: April 1, 2008 /s/ ALLEN RUBY Counsel for Barry L. Bonds DATED: April 1, 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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