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United States v. Truong

March 18, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
VI TRUONG, AKA KEN VI TRUONG, GARY TRUONG, AND RAYMOND PABLO RAMOS, DEFENDANTS.



The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED] ORDER

Date: March 19, 2010 Time: 9:00 a.m. Judge: Garland E. Burrell, Jr.

IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendants, VI TRUONG, aka Ken Vi Truong, GARY TRUONG, and RAYMOND PABLO RAMOS, through their respective attorneys, that the Court should vacate the status conference scheduled for March 19, 2010, at 9:00 a.m., and reset it for April 9, 2010, at 9:00 a.m.

Counsel for defendants require further time to review discovery and to negotiate with the government in an effort to resolve this matter.

It is further stipulated by the parties that the Court should exclude the period from the date of this order through April 9, 2010, when it computes the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act. The parties stipulate that the ends of justice served by granting defendants' request for a continuance outweigh the best interest of the public and the defendants' in a speedy trial, and that this is an appropriate exclusion of time for defense preparation within the meaning of 18 U.S.C. § 3161(h)(7)(A) and (B) (Local Code T4).

Dated: March 16, 2010

Respectfully submitted,

DANIEL BRODERICK Federal Defender

MICHAEL PETRIK, Jr. Assistant Federal Defender Attorneys for Defendant

Dated: March 16, 2010

M. Petrik for Douglas Horngrad

DOUGLAS HORNGRAD Attorney for VI TRUONG

Dated: March 16, 2010

M. Petrik for Dina ...


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