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United States v. Samuel

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


October 22, 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, AND RONALD BURRIS, JR., DEFENDANTS.

The opinion of the court was delivered by: Hon. John A. Mendez

Date: January 11, 2011

STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE

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, and RONALD BURRIS, JR., by and through their respective counsel, that the status conference in the above-captioned matter set for Tuesday, October 26, 2010, be continued to Tuesday, January 11, 2011, 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, October 26, 2010, through the date of the status conference set for January 11, 2011, 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 46,000 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: October 22, 2010

PHILIP A. FERRARI Assistant U.S. Attorney

DATE: October 22, 2010

By: Philip A. Ferrari for SCOTT TEDMON Counsel for Defendant HODA SAMUEL

DATE: October 22, 2010

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

DATE: October 22, 2010

By: Philip A. Ferrari for DONALD HELLER Counsel for Defendant CHARLES ROBERT MANESS

DATE: October 22, 2010

By: Philip A. Ferrari for THOMAS JOHNSON Counsel for Defendant SEAN GJERDE

DATE: October 22, 2010

By: Philip A. Ferrari for MICHAEL PETRIK, JR. Counsel for Defendant TRACY PAINTER

DATE: October 22, 2010

By: Philip A. Ferrari for ADANTE DE POINTER Counsel for Defendant DANA FAULKNER

DATE: October 22, 2010

By: Philip A. Ferrari for MICHAEL BIGELOW Counsel for Defendant NICOLE DAWSON

DATE: October 22, 2010

By: Philip A. Ferrari for JOSEPH J. WISEMAN Counsel for Defendant YGNACIA BRADFORD

DATE: October 22, 2010

By: Philip A. Ferrari for MICHAEL E. HANSEN Counsel for Defendant RONALD BURRIS, JR.

IT IS SO FOUND AND ORDERED.

HON. JOHN A. MENDEZ UNITED STATES DISTRICT JUDGE

20101022

© 1992-2010 VersusLaw Inc.



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