The opinion of the court was delivered by: Judge Susan Illston United States District Court
AMENDED JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE MOTIONS HEARING AND ALTER BRIEFING SCHEDULE AND EXCLUDE TIME
WHEREAS the United States Attorney's Office of the Northern District of California conferred with counsel for Vince Wan, Alex Fong, Michael Leung, and Kitty Li (collectively, the "Parties") regarding scheduling and further attempts to resolve this matter.
WHEREAS, defense motions currently are scheduled to be heard on August 22, 2008 24 at 11:00 a.m., with defense motions having been due on June 27, 2008, opposition briefs due 25 on July 25, 2008, and reply briefs due on August 12, 2008.
WHEREAS, the Parties wish to continue discussions regarding possible resolution of the case and counsel for the defendants require additional time to complete review of 28 voluminous discovery prior to filing their motions.
WHEREAS, the Parties previously stipulated and proposed a new hearing date and briefing schedule, where counsel for Vince Wan, in error, stipulated to a new hearing date of September 12, 2008, and counsel for Mr. Wan also having been informed by the Court's clerk that September 12, 2008, in fact may be unavailable, and the Court's clerk having advised that the Parties file their request for September 19, 2008,
THE PARTIES hereby agree and respectfully request that the motions hearing be postponed to September 19, 2008, at 11:00 a.m., with defense motions due July 18, 2008, opposition briefs due August 15, 2008, and reply briefs due September 2, 2008.
THE PARTIES FURTHER hereby agree and respectfully request that the period from June 27, 2008, through September 19, 2008, be excluded from the otherwise applicable Speedy Trial computation, pursuant to 18 U.S.C. §§ 3161(h)(8)(A) and (B)(ii) and (iv).
NICOLE KIM Attorney for Plaintiff
LAW OFF OF DOUGLAS I. HORNGRAD
DOUGLAS I. HORNGRAD Attorney for ...