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 JUNE 30, 2017 TO 

JULY 14, 2017

IT IS HEREBY STIPULATED between the parties, Assistant United States Attorney, Michelle 

Bazu for Plaintiff United States of America, and Doron Weinberg, counsel for defendant Dangelo 

Currie, that the status conference hearing presently scheduled for Friday, June 30, 2017 at 9:30 a.m., be 

continued to Friday, July 14, 2017 at 9:30 a.m. 

The parties agree to exclude the time between June 30, 2017 and July 14, 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 produced discovery additional discovery on June 28, 2017. Defense counsel 

continues to review the discovery, conduct further investigation and research, and will need additional 

time to discuss the discovery and the case with the defendant. Therefore, the parties agree that the time 
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00090 JST

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period of June 30, 2017 and July 14, 2017, inclusive, should be excluded pursuant to 18 U.S.C. §§ 

3161(h)(7)(A) and (h)(7)(B)(iv) on the basis that 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, taking into account the exercise of 

due diligence. 

DATED: June 28, 2017 /s/

DORON WEINBERG

Counsel for Dangelo Currie

DATED: June 28, 2017 /s/

MICHELLE BAZU

Assistant United States Attorney
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

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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 June 30, 2017 through July 14, 2017 would deny counsel the 

reasonable time necessary for effective preparation, 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 June 30, 2017 through July 14, 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 June 30, 2017 through July 14, 2017 shall be excluded from computation 

under the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). 

DATED: June 29, 2017 _________________________________

HONORABLE JON S. TIGAR

United States District Judge