Stipulation and Proposed Order to Exclude Time from August 21 to September 11, 2024, Under the Speedy Trial Act — United States v. Cassie Will-Darnall (Dkt. 19)

Summary

The United States and the defense submit a stipulation and proposed order to exclude time under the Speedy Trial Act in United States v. Cassie Will-Darnall. The stipulation recites that on August 21, 2024, the parties appeared before the Honorable P. Casey Pitts for a status conference and the Court set a change of plea hearing for September 11, 2024. It states that defense counsel needs additional time to review discovery, conduct his own investigation, and prepare, and that the Court granted the request. The parties stipulate that time from August 21, 2024, through September 11, 2024, should be excluded, and the signature blocks of the Assistant United States Attorney and the Assistant Federal Public Defender show /s/.

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“Stipulation and Proposed Order to Exclude Time from August 21 to September 11, 2024, Under the Speedy Trial Act — United States v. Cassie Will-Darnall (Dkt. 19).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-19-0-b210e8735e/, SHA-256 91b0b241b3734222695f3f21e073be44ff6c887dec79df3c92fbdd434b9ade12.

Full text

Case 5:24-cr-00292-PCP Document 19 Filed 08/22/24 Page 1 of 3

1 ISMAIL J. RAMSEY (CABN 189820)
United States Attorney
2
MARTHA BOERSCH (CABN 126569)
3 Chief, Criminal Division

4 SARAH E. GRISWOLD (CABN 240326)
Assistant United States Attorney
5
150 Almaden Boulevard, Suite 900
6 San Jose, California 95113
Telephone: (408) 535-5061
7 FAX: (408) 535-5081
sarah.griswold@usdoj.gov
8
Attorneys for United States of America
9
UNITED STATES DISTRICT COURT
10
NORTHERN DISTRICT OF CALIFORNIA
11
SAN JOSE DIVISION
12

13 UNITED STATES OF AMERICA, ) CASE NO. 5:24-CR-292 PCP
)
14 Plaintiff, ) STIPULATION AND [PROPOSED] ORDER TO
) EXCLUDE TIME FROM AUGUST 21 2024,
15 v. ) THROUGH SEPTEMBER 11, 2024, FROM THE
) SPEEDY TRIAL ACT CALCULATION UNDER 18
16 CASSIE WILL-DARNALL, ) U.S.C. § 3161(h)(7)(A) AND (h)(7)(B)(iv)
)
17 Defendant. )
)
18 )
)
19

20 On August 21, 2024, the parties appeared before the Honorable P. Casey Pitts for a status
21 conference in this case. At this hearing, the Court set a change of plea hearing for September 11, 2024.

22 Defense counsel needs additional time to review discovery, conduct his own investigation, and prepare

23 for the change of plea hearing. Defense counsel requested a continuance and exclusion of time. The

24 Court granted the request. The parties hereby submit this joint stipulation to effectuate the Court’s order

25 to exclude time from August 21, 2024, through August 5, 2024, from the Speedy Trial Act calculation.

26 The parties hereby stipulate that the time from August 21, 2024, through September 11, 2024,
27 should be excluded from the period of time within which the defendants’ trial must commence pursuant

28 to the Speedy Trial Act in order to allow defense counsel sufficient time to prepare effectively, taking

STIP. & PROP’D ORDER 1
5:24-CR-292 PCP
Case 5:24-cr-00292-PCP Document 19 Filed 08/22/24 Page 2 of 3

1 into account the exercise of due diligence. Furthermore, the parties stipulate that the ends of justice

2 served by granting the request outweigh the best interest of the public and the defendants in a speedy

3 trial.

5 Respectfully submitted,

6 DATED: August 21, 2024 ISMAIL J. RAMSEY
United States Attorney
7

8 /s/
SARAH E. GRISWOLD
9 Assistant United States Attorney

10
JODI LINKER
11 Federal Public Defender
12 DATED: August 21, 2024 /s/
VARELL L. FULLER
13 Assistant Federal Public Defender
Counsel for Defendant Cassie Will-Darnall
14

18
19

STIP. & PROP’D ORDER 2
5:24-CR-292 PCP
Case 5:24-cr-00292-PCP Document 19 Filed 08/22/24 Page 3 of 3

1 ORDER

2 Based upon the representations made at the status conference on August 21, 2024, and in the

3 parties’ stipulation above, and for good cause shown, the COURT HEREBY ORDERS that the time

4 between August 21, 2024, and September 11, 2024, is excluded under the Speedy Trial Act, 18 U.S.C.

5 § 3161(h)(7)(A) and 3161(h)(7)(B)(iv). The Court finds that defense counsel needs additional time to

6 review discovery and investigate this matter, and that the failure to grant this request would

7 unreasonably deny defense counsel reasonable time to effectively prepare, taking into account the

8 exercise of due diligence. Furthermore, the Court finds that the ends of justice served by granting the

9 request outweigh the best interest of the public and the defendants in a speedy trial and in the prompt

10 disposition of criminal cases. The Court therefore excludes this time pursuant to 18 U.S.C.

11 § 3161(h)(7)(A) and 3161(h)(7)(B)(iv).

14 DATED: August ___, 2024 ___________________________________
HON. P. CASEY PITTS
15 UNITED STATES DISTRICT JUDGE
16

18
19

STIP. & PROP’D ORDER 3
5:24-CR-292 PCP

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