IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 28, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
TONY Q. LE, ET.AL. DEFENDANT.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from August 31, 2009 to October 19, 2009 at 8:30 a.m. They stipulate that the time between August 31, 2009 and October 19, 2009 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Specifically, this case involved five defendant, most whom require the services of an interpreter. Defense counsel are still reviewing the discovery in the case and performing investigation in this matter. Additionally, Defense Counsel Linsay Weston was recently appointed to represent Defendant Tien Le, replacing Mr. Bauer, and will need additional time to become familiar with the case and perform her own investigation in the matter. All defense counsel need additional time to confer with each other and review a proposed settlement offer from the government with the defendants. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
DATE: August 28, 2009 JOSEPH WISEMAN Attorney for Defendant Tony Le. DAN KOUKOL Attorney for Defendant Cuong Le. ALICE W. WONG Attorney for Defendant Hung Le. WILLIAM PORTANOVA Attorney for Defendant Minh Le. LINDSAY WESTON Attorney for Defendant Tien Le.
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