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United States v. Khalil

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


September 18, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HIDAYATULLAH ALI KHALIL, DEFENDANT.

The opinion of the court was delivered by: Hon. William B. Shubb

STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF STATUS CONFERENCE

Date: September 21, 2009

It is hereby stipulated and agreed to between the United States of America through SEAN C. FLYNN, Assistant United States Attorney, and defendant, HIDAYATULLAH ALI KHALIL, by and through his attorney THOMAS A. JOHNSON, that the status conference in the above-captioned matter set for Monday, September 21, 2009, be continued to Monday, October 19, 2009, at 8:30 a.m.

The parties further stipulate that the time period from September 21, 2009, up to and including the new status conference date of October 19, 2009, should be excluded from computation of the time for commencement of trial 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). Specifically, the defense agrees that it needs additional time to continue discussions with the government regarding potential resolution of the case against the defendant, review produced discovery in the case, and effectively evaluate the posture of the case and potentially prepare for trial. See id. For these reasons, the defendant, defense counsel, and the government 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); Local Code T4.

Respectfully Submitted,

LAWRENCE G. BROWN United States Attorney

DATE: September 18, 2009

SEAN C. FLYNN Assistant U.S. Attorney

THOMAS A. JOHNSON Atty. for Hidayatullah Ali Khalil

IT IS SO ORDERED.

20090918

© 1992-2009 VersusLaw Inc.



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