USA v. Mailloux Document 12: Motion for Excludable Delay

Massachusetts District Court
Case No. 1:05-cr-10080-NG
Filed May 19, 2005

Assented to MOTION for Excludable Delay from March 29, 2005 to June 15, 2005 as to Rob Maillouxby USA. (Ortiz, Carmen)

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Page 1 Case 1:05-cr-10080-NG
Document
Filed 05/19/
Page 1 of
UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
UNITED STATES OF AMERICA
v.
ROB MAILLOUX, a/k/a
Oscar E. Mailloux, Jr.
Defendant
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CRIMINAL NO.
05-10080-NG
ASSENTED-TO MOTION TO EXCLUDE TIME FROM
MARCH 29, 2005 THROUGH AND INCLUDING JUNE 15, The United States of America, with the assent of the
Defendant, hereby moves this Honorable Court pursuant to United
States Code §3161(h)(8)(A) that the period from March 29, 2005,
the date of the Defendant’s Initial Appearance, through May 11,
2005, the date when the Initial Status Conference was held in
this matter, up to and including June 15, 2005, the date on which
a Final Status Conference is scheduled to be held, be excluded
from computation under the Speedy Trial Act of the time within
which this case must be tried.
As reasons therefore, the parties
represent that this time has been necessary to allow the
defendant to obtain discovery and complete his review of the
materials made available by the government, and to determine what
motions, if any, may appropriately be filed pursuant to Fed. R.
Crim. P. 12(c).
Additionally, the parties need an opportunity to
further discuss resolving this case short of trial.
An order
permitting such exclusion may properly be entered upon finding by
the Court that the ends of justice served by granting such an
exclusion outweigh the best interests of the public and the
Page 2 Case 1:05-cr-10080-NG
Document
Filed 05/19/
Page 2 of
defendant in a speedy trial.
WHEREFORE, the parties respectfully request that the Court
enter a written order of excludable delay covering the period
from March 29, 2005 through June 15, 2005, for a total of days.
Respectfully submitted,
MICHAEL J. SULLIVAN
United States Attorney
By:
/s/ Carmen M. Ortiz
Carmen M. Ortiz
Assistant U.S. Attorney
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