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United States v. Samuel

July 29, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
HODA SAMUEL, CONNIE DEVERS, CHARLES ROBERT MANESS, DANA FAULKNER, TRACY PAINTER, YGNACIA BRADFORD, SEAN PATRICK GJERDE, NICOLE DAWSON, DANIEL HARRISON, AND RONALD BURRIS, JR., DEFENDANTS.



The opinion of the court was delivered by: Hon. John A. Mendez United States District Judge

STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE

Date: September 14, 2010 Time: 9:30 a.m. Hon. John A. Mendez

It is hereby stipulated and agreed to between the United States of America through PHILIP A. FERRARI, Assistant United States Attorney, and defendants HODA SAMUEL, CONNIE DEVERS, CHARLES ROBERT MANESS, DANA FAULKNER, TRACY PAINTER, YGNACIA BRADFORD, SEAN PATRICK GJERDE, NICOLE DAWSON, DANIEL HARRISON, and RONALD BURRIS, JR., by and through their respective counsel, that the status conference in the above-captioned matter set for Tuesday, August 3, 2010, be continued to Tuesday, September 14, 2010, at 9:30 a.m.

The parties request that the Court exclude from calculation under the Speedy Trial Act the time from the date of the originally set status conference, August 3, 2010, through the date of the status conference set for September 14, 2010, pursuant to 18 U.S.C. §§ 3161(h)(7)(B)(ii) and (iv) [complexity and reasonable time to prepare] (Local Codes T2 and T4). Since the Indictment was filed on June 10, 2010, the government has produced over 34,000 documents to counsel for the defendants. 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 time to review the discovery, investigate the facts underlying this case and seek possible resolution. Additionally, the parties 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.

IT IS SO STIPULATED.

DATE: July 29, 2010

PHILIP A. FERRARI Assistant U.S. Attorney

DATE: July 29, 2010

Philip A. Ferrari for SCOTT TEDMON

Counsel for Defendant HODA SAMUEL

DATE: July 29, 2010

Philip A. Ferrari for MARK REICHEL Counsel for Defendant CONNIE DEVERS

DATE: July 29, 2010

Philip A. Ferrari for DONALD HELLER Counsel ...


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