STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00090 JST

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BRIAN J. STRETCH (CABN 163973)

United States Attorney

BARBARA J. VALLIERE (DCBN 439353)

Chief, Criminal Division

MICHELLE BAZU (CABN 266964)

Assistant United States Attorney

1301 Clay Street, Suite 340S

Oakland, California 94612

Telephone: (510) 637-3680

FAX: (510) 637-3724

michelle.bazu@usdoj.gov

Attorneys for United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

DANGELO CURRIE,

Defendant.

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Case No.: CR 17-00090 JST

STIPULATION AND [PROPOSED] ORDER 

EXCLUDING TIME FROM MAY 26, 2017 TO 

JUNE 16, 2017

On May 26, 2017, the defendant Dangelo Currie, represented by Angela Hansen, Assistant 

Federal Public Defender (special appearance), and the government, represented by Michelle Bazu, 

Assistant United States Attorney, appeared before the Honorable Jon S. Tigar for a status conference. 

The matter was continued to June 16, 2017 at 9:30 a.m. to set further proceedings. 

The parties agree to exclude the time between May 26, 2017 and June 16, 2017 from the time in 

which the defendant must be brought to trial pursuant to the Speedy Trial Act, 18 U.S.C. § 3131 et al. 

The government has recently produced discovery, and additional discovery will be produced shortly to 

defense counsel. Therefore, the parties agree that the time period of May 26, 2017 and June 16, 2017, 

inclusive, should be excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (h)(7)(B)(iv) on the basis that 
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00090 JST

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the ends of justice served by the continuance outweigh the best interests of the public and defendant in a 

speedy trial, and failing to exclude this time would deny counsel the reasonable time necessary for 

effective preparation, as well as continuity of counsel, taking into account the exercise of due diligence. 

DATED: May 26, 2017 /s/

DORON WEINBERG

Counsel for Dangelo Currie

DATED: May 26, 2017 /s/

MICHELLE BAZU

Assistant United States Attorney
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00090 JST

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ORDER

Based upon the representations of counsel and for good cause shown, the Court finds that failing 

to exclude the time between from May 26, 2017 through June 16, 2017 would deny counsel the 

reasonable time necessary for effective preparation, as well as continuity of counsel, taking into account 

the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The Court further finds that the ends of 

justice served by excluding the time from May 26, 2017 through June 16, 2017 from computation under 

the Speedy Trial Act outweigh the best interests of the public and the defendant in a speedy trial. 

Therefore, IT IS HEREBY ORDERED that the time from May 26, 2017 through June 16, 2017 shall 

be excluded from computation under the Speedy Trial Act. 18 U.S.C. §§ 3161(h)(7)(A) and 

(h)(7)(B)(iv). 

DATED: May 26, 2017 _ _________________________________

HONORABLE JON S. TIGAR

United States District Judge