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United States v. Chang

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


April 8, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HENRY CHANG, ET AL., DEFENDANTS.

The opinion of the court was delivered by: Judge Hon. Garland E. Burrell

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE Date: 4/10/09 Time: 9:00 a.m.

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Michael M. Beckwith, Esq., Assistant United States Attorney, together with counsel for defendant Jason Lee, Fred N. Dawson, Esq., and defendant Henry Chang, Kenny Giffard, Esq., that the status conference presently set for April 10, 2009 be continued to April 24, 2009, at 9:00 a.m., thus vacating the presently set status conference. Counsel for the parties agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code § 3161(h)(8)(B)(iv) (continuity of counsel/ reasonable time for effective preparation, specifically the defense would like time to review proposed plea agreements) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference April 24, 2009.

IT IS SO STIPULATED.

Dated: April 7, 2009

[PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

GOOD CAUSE APPEARING, it is hereby ordered that the April 10, 2009 status conference be continued to April 24, 2009 at 9:00 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv) and Local Code T4 from the date of this order to April 24, 2009.

IT IS SO ORDERED.

GARLAND E. BURRELL, JR. United States District Judge

20090408

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