The opinion of the court was delivered by: Hon. William B. Shubb
STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF STATUS CONFERENCE
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 counsel, that the status conference in the above-captioned matter set for Monday, April 12, 2010, be continued to Monday, April 19, 2010, at 8:30 a.m.
The parties further stipulate that the time period from April 12, 2010, up to and including the new status conference date of April 19, 2010, 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 defense counsel 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, defendant agrees that his counsel needs additional time to continue discussions with the government regarding potential resolution of the case, review produced discovery in the case, and effectively evaluate the posture of the case and potentially prepare for trial. See id.
For these reasons, 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)(B)(iv) (Local Code T4).
BENJAMIN B. WAGNER United States Attorney
SEAN C. FLYNN Assistant U.S. Attorney
TOM JOHNSON Counsel for defendant Khalil
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