IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 23, 2010
UNITED STATES OF AMERICA, PLAINTIFF,
STEPHEN KRAUT, DEFENDANT.
The opinion of the court was delivered by: Hon. Edward J. Garcia United States District Court Judge
Stipulation to Continue Status Conference & Order Date: October 22, 2010 Time: 10:00 a.m.
Court: Hon. Edward J. Garcia
Defendant, Stephen Kraut, by and through his undersigned counsel and the United States, by and through Assistant United States Attorney Russell Carlberg, hereby agree and stipulate that the status conference previously scheduled for August 27, 2010 should be continued to October 22, 2010, and that date is available with the Court.
The reasons for this request are that Mr. Kraut has received and reviewed with both his attorney and investigator, well in excess of 100,000 pages of discovery, as well as boxes of discovery at the F.B.I. office in Sacramento. In addition, there is a warehouse of documents which have direct bearing on the loss amount in this case and are vital to resolving the matter. The parties are in the process of setting up a categorical review of all of those documents. The allegations in this case span over a year time period and involve many documents, which counsel has been in the process of reviewing and investigating. There are complicated loss issues that need to be resolved before the parties can engage in meaningful negotiations. The parties agree that the status conference should be continued to October 22, 2010 to allow the defense investigator to prepare a reasonable estimate on loss. This case is complex and counsel requires adequate time to prepare a defense. Time should be excluded for complexity and preparation of counsel under 18 U.S.C. § 3161(H)(8)(b)and under § 3161 (h)(1)(D) and pursuant to local code T2 and T4.
Respectfully submitted, Shari Rusk Dated: August 20, 2010 Attorney for Defendant
Stephen Kraut Russell Carlberg Dated: August 20, 2010 Assistant United States Attorney
IT IS SO ORDERED.
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