Stipulation and Proposed Order to Continue Change of Plea Hearing — United States v. Cassie Will-Darnall (Dkt. 21)

Summary

A Stipulation and [Proposed] Order to Continue Change of Plea Hearing in United States of America v. Cassie Will-Darnall, No. CR 24-00292 PCP, Document 21, filed September 5, 2024, in the U.S. District Court for the Northern District of California. The parties stipulate, subject to the Court's approval, that the change of plea hearing set for September 11, 2024, at 10:00 a.m., be continued to October 9, 2024, at 10:00 a.m. The stated reason is that defense counsel requires additional time to research and investigate an issue that is material to a possible negotiated disposition. The parties also agree that time may be excluded under the Speedy Trial Act between September 11, 2024 and October 9, 2024, citing 18 U.S.C. § 3161(h)(7)(A). The signature lines for Varell L. Fuller and Sarah E. Griswold show /s/.

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“Stipulation and Proposed Order to Continue Change of Plea Hearing — United States v. Cassie Will-Darnall (Dkt. 21).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-21-0-aa66a527c3/, SHA-256 6653c09b2f64d489a70469cd1cb86336a0f0341ab7b80b36f85a2e1acac5b30b.

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Case 5:24-cr-00292-PCP Document 21 Filed 09/05/24 Page 1 of 3

1 JODI LINKER
Federal Public Defender
2
VARELL L. FULLER
3 Assistant Federal Public Defender
55 S. Market Street, Suite 820
4 San Jose, CA 95113
5
Telephone: (408) 291-7753
Fax: (408)-291-7399
6 Varell_Fuller@fd.org
7 Counsel for Defendant WILL-DARNALL
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
SAN JOSE DIVISION
11

12
UNITED STATES OF AMERICA, No. CR 24-00292 PCP
13
Plaintiff, STIPULATION AND [PROPOSED] ORDER
14 TO CONTINUE CHANGE OF PLEA
v. HEARING
15
CASSIE WILL-DARNALL,
16
Defendant.
17

18 STIPULATION
19
The parties, acting through their respective counsel, hereby stipulate, subject to the
20

21
Court’s approval, that the change of plea hearing currently set for September 11, 2024, at 10:00

22 a.m., be continued to October 9, 2024, at 10:00 a.m. The reason for the continuance is defense
23 counsel requires additional time to research and investigate an issue that is material to a possible
24
negotiated disposition
25
Accordingly, the parties stipulate and agree that time may be excluded under the Speedy
26

27 Trial Act between September 11, 2024, and October 9, 2024, for effective preparation of counsel

28 and in the interest of justice. 18 U.S.C. § 3161(h)(7)(A).

STIPULATION AND [PROPOSED] ORDER
CR 24-00292-PCP
Case 5:24-cr-00292-PCP Document 21 Filed 09/05/24 Page 2 of 3

2
IT IS SO STIPULATED.
3

4 Dated: September 5, 2024 JODI LINKER
5
Federal Public Defender
___________/s/_______________
6 VARELL L. FULLER
Assistant Federal Public Defender
7

8
Dated: Seotember 5, 2024, ISMAIL J. RAMSEY
9 United States Attorney
__________/s/________________
10
SARAH E. GRISWOLD
11 Assistant United States Attorney

12
[PROPOSED] ORDER
13

14 GOOD CAUSE APPEARING, and upon stipulation of the parties, IT IS HEREBY

15 ORDERED that the change of plea hearing currently set for September 11, at 10:00 a.m., shall
16
be continued to October 9, 2024, at 10:00 a.m.
17
IT IS FURTHER ORDERED that the time from September 11, 2024, through and
18
including October 9, 2024, is excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(A)
19

20 and 3161(h)(7)(B)(iv).

21 THE COURT FINDS that failing to exclude the time from September 11, 2024, through
22
and including October 9, 2024, would unreasonably deny defense counsel the reasonable time
23
necessary for effective preparation, taking into account the exercise of due diligence. See 18
24

25
U.S.C. §3161(h)(7)(B)(iv).

26 THE COURT FURTHER FINDS that the ends of justice served by excluding the time
27
from September 11, 2024, through and including October 9, 2024, from computation under the
28

STIPULATION AND [PROPOSED] ORDER
CR 24-00292-PCP
Case 5:24-cr-00292-PCP Document 21 Filed 09/05/24 Page 3 of 3

1 Speedy Trial Act outweigh the interests of the public and the defendant in a speedy trial. The
2
Court therefore excludes this time pursuant to 18 U.S.C. § 3161(h)(7)(A) and 3161(h)(7)(B)(iv).
3
IT IS SO ORDERED.
4

6 DATED: ___________ _____________________________________
HONORABLE P. CASEY PITTS
7 United States District Judge
8

STIPULATION AND [PROPOSED] ORDER
CR 24-00292-PCP

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