The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
STIPULATION AND PROPOSED ORDER FOR EXCLUSION OF TIME UNTIL NEXT STATUS CONFERENCE Date: June 25, 2010 Time: 9:00 a.m.
On June 25, 2010, the parties to the above-captioned criminal matter appeared for a status conference before the Honorable Garland E. Burrell. After discussion with counsel, the Court set a further status conference in the case for Friday, July 23, 2010, at 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, MITCHELL WRIGHT, HAIYING FAN, and GARY GEORGE, by and through their respective counsel, that the time period from June 25, 2010, up to and including the new status conference date of July 23, 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: June 29, 2010 SEAN C. FLYNN Assistant U.S. Attorney
DATE: June 29, 2010 ROBERT BELES Counsel for Dennis Aaron Moore
DATE: June 29, 2010 SCOTT A. SUGARMAN Counsel for Mitchell B. Wright
DATE: June 29, 2010 MICHAEL B. BIGELOW Counsel for Gary Lorenzo George
DATE: June 29, 2010 CHRISTOPHER H. WING Counsel for Haiying Fan
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