The opinion of the court was delivered by: Hon. Garland E. Burrell
STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF STATUS CONFERENCE Date: April 30, 2010 Time: 9:00 a.m.
It is hereby stipulated and agreed to between the United States of America through SEAN C. FLYNN, Assistant United States Attorney, and defendants, DENNIS MOORE, VERONIKA WRIGHT, MITCHELL WRIGHT, HAIYING FAN, and GARY GEORGE, by and through their respective counsel, that the status conference in the above-captioned matter set for Friday, April 30, 2010, be continued to Friday, June 4, 2010, at 9:00 a.m.
The parties further stipulate that the time period from April 30, 2010, up to and including the new status conference date of June 4, 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 each 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, each defendant agrees that his or her 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. Additionally, the parties continue to stipulate that the above-captioned case is unusual and complex such that it is unreasonable to expect adequate preparation for pretrial proceedings or for a potential trial within the time limits established by the Speedy Trial Act.
For these reasons, the defendants, 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); 18 U.S.C. § 3161(h)(7)(B)(ii) (Local Code T2).
Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney DATE: May 5, 2010 By: /s/ Sean C. Flynn SEAN C. FLYNN Assistant U.S. Attorney Anne C. Beles by SCF
DATE: May 5, 2010 ANNE C. BELES Counsel for Dennis Aaron Moore Roger W. Patton by SCF
DATE: May 5, 2010 ROGER W. PATTON Counsel for Veronika Wright Scott A. Sugarman by SCF
DATE: May 5, 2010 SCOTT A. SUGARMAN Counsel for Mitchell B. Wright Michael Bigelow by SCF
DATE: May 5, 2010 MICHAEL B. BIGELOW Counsel for Gary Lorenzo George Christopher H. Wing by SCF
DATE: May 5, 2010 CHRISTOPHER H. WING Counsel for Haiying Fan
GARLAND E. BURRELL, JR. United States District Judge
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