STIP. AND [PROPOSED] ORDER 1

CR-17-00040-RS

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

BRIAN J. STRETCH (CABN 163973)

United States Attorney

BARBARA VALLIERE (DCBN 439353)

Chief, Criminal Division

MICHAEL MAFFEI (CABN 240978)

KAREN KREUZKAMP (CABN 246151)

Assistant United States Attorneys

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-7246

Fax: (415) 436-7207

Email: Michael.Maffei@usdoj.gov

Attorneys for United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

MARC CHRISTOPHER BROCKHAUS,

Defendant.

)

)

)

)

)

)

)

)

)

)

CASE NO. CR-17-00040-RS

[PROPOSED] ORDER AND

STIPULATION TO CONTINUE AND EXCLUDE

TIME FROM THE SPEEDY TRIAL ACT

CALCULATION

With the agreement of the parties, and with the consent of the defendant, the Court enters this 

order vacating the currently scheduled status conference on Tuesday, March 28, 2017, and orders the 

matter re-set on Tuesday, April 4, 2017 at 2:30 p.m. for a change of plea or trial setting, and confirms

the exclusion of time under the Speedy Trial Act, 18 U.S.C. § 3161(b), from March 28, 2017 to April 4,

2017. The parties agree, and the Court finds and holds, as follows:

1. The parties have been in discussion about a resolution in this matter, and believe that a short 

continuance is warranted to finalize a plea agreement and to allow the defense to continue to review the 

discovery provided by the government. Therefore, the parties respectfully request that the Court vacate 

the currently scheduled status date of Tuesday, March 28, 2017, and re-set the matter for Tuesday, April 

4, 2017, at 2:30 p.m. for a change of plea or trial setting.

Case 3:17-cr-00040-RS Document 15 Filed 03/27/17 Page 1 of 2
STIP. AND [PROPOSED] ORDER 2

CR-17-00040-RS

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

2. The defendant agrees to an exclusion of time under the Speedy Trial Act, 18 U.S.C. §

3161(h)(8)(B)(iv) to provide reasonable time necessary for effective preparation, taking into account the 

exercise of due diligence.

3. The Court finds that, taking into the account the public interest in the prompt disposition of 

criminal cases, these grounds are good cause for excluding time. Given these circumstances, the Court 

finds that the ends of justice served by excluding the period from March 28, 2017 through and including

April 4, 2017, outweigh the best interest of the public and the defendant in a speedy trial. 18 U.S.C. §

3161(h)(8)(A).

4. Accordingly, and with the consent of the defendant, the Court ORDERS THAT:

(1) the currently-scheduled status date of March 28, 2017 shall be vacated;

(2) the matter shall be re-set for April 4, 2017, at 2:30 p.m. for a change of plea or trial 

setting; and

(3) the period from March 28, 2017 through and including April 4, 2017, shall be 

excluded from the Speedy Trial Act calculations under 18 U.S.C. § 3161(h)(8)(A).

IT IS SO STIPULATED.

DATED: March 27, 2017 BRIAN J. STRETCH

United States Attorney

/s/

MICHAEL MAFFEI

KAREN KREUZKAMP

Assistant United States Attorney

DATED: March 27, 2017

/s/

JONATHAN MCDOUGALL

Counsel for the Defendant

IT IS SO ORDERED.

DATED:

HON. RICHARD SEEBORG

United States District Judge

3/27/17

Case 3:17-cr-00040-RS Document 15 Filed 03/27/17 Page 2 of 2