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STIP. (1) CONT. PRELIM. HRG. OR ARR. DATE; & (2) 

EXCLUDING TIME UNDER THE STA AS DELAY 

RESULTING FROM DEFERRAL OF PROSECUTION; 

[PROPOSED] ORDER No.: CR 3-05-70262 JL

KEVIN V. RYAN (CSBN 118321)

United States Attorney

EUMI L. CHOI (WVBN 0722)

Chief, Criminal Division

MONICA FERNANDEZ (CSBN 168216)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-7065

FAX: (415) 436-7234

E-mail: Monica.L.Fernandez@usdoj.gov

Attorneys for Plaintiff

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

TIFFANY STUART, aka Jane Doe,

JENNIFER LANGE, and

BRANDY DOUGLAS,

Defendants.

 

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No.: CR 3-05-70262 JL

STIPULATION (1) CONTINUING

PRELIMINARY HEARING OR

ARRAIGNMENT DATE; AND (2) 

EXCLUDING TIME UNDER THE SPEEDY

TRIAL ACT AS DELAY RESULTING

FROM DEFERRAL OF PROSECUTION;

[PROPOSED] ORDER

The parties to the above case hereby stipulate as follows:

1. This matter is currently set for preliminary hearing or arraignment on September

 6, 2005.

2. The defendants have each entered into written pre-trial diversion agreements with the United

States Attorney.

3. Accordingly, the parties agree as follows:

Case 3:05-mj-70262-MAG Document 62 Filed 09/06/05 Page 1 of 3
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STIP. (1) CONT. PRELIM. HRG. OR ARR. DATE; & (2) 

EXCLUDING TIME UNDER THE STA AS DELAY 

RESULTING FROM DEFERRAL OF PROSECUTION; 

[PROPOSED] ORDER No.: CR 3-05-70262 JL 2

a. This matter should be continued for one year, until September 6, 2006.

b. Time should be excluded under the Speedy Trial Act as delay resulting from deferral

of prosecution pursuant to 18 U.S.C. Section 3161(h)(2).

IT IS SO STIPULATED.

DATED: September 2, 2005 Respectfully submitted,

KEVIN V. RYAN

United States Attorney

/s/ Monica Fernandez 

MONICA FERNANDEZ

Assistant United States Attorney

DATED: September 2, 2005 /s/ Daniel Blank for 

JOSH COHEN, ESQ.

Assistant Federal Public Defender

Attorney for Defendant Stuart

DATED: September 1, 2005 /s/ Suzanne Luban 

SUZANNE LUBAN, ESQ.

Attorney for Defendant Lange

/s/ Peter Goodman for 

DATED: September 2, 2005 GEOFFREY ROTWEIN, ESQ.

Attorney for Defendant DOUGLAS

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STIP. (1) CONT. PRELIM. HRG. OR ARR. DATE; & (2) 

EXCLUDING TIME UNDER THE STA AS DELAY 

RESULTING FROM DEFERRAL OF PROSECUTION; 

[PROPOSED] ORDER No.: CR 3-05-70262 JL 3

ORDER

Pursuant to the parties’ stipulation, this matter is continued until September 6, 2006. 

In light of the written pre-trial diversion agreements entered into between the defendants and

the United States Attorney, time is excluded under the Speedy Trial Act from September 6, 2005

through September 6, 2006. See 18 U.S.C. Section 3161(h)(2).

PURSUANT TO STIPULATION, IT IS SO ORDERED.

DATED: September 6, 2005 ___________________________________

HONORABLE JOSEPH C. SPERO

UNITED STATES MAGISTRATE JUDGE

Case 3:05-mj-70262-MAG Document 62 Filed 09/06/05 Page 3 of 3