STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF STATUS CONFERENCE Date: June 14, 2010 Time: 8:30 a.m.
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, May 24, 2010, be continued to Monday, June 14, 2010, at 8:30 a.m.
The parties further stipulate that the time period from May 24, 2010 up to and including the new status conference date of June 14, 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).
Respectfully Submitted, BENJAMIN B. WAGNER United States Attorney DATE: May 20, 2010 SEAN C. FLYNN Assistant U.S. Attorney
DATE: May 20, 2010 TOM JOHNSON Counsel for defendant Khalil
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