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United States of America v. Vi Truong

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


December 8, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
VI TRUONG, AKA KEN VI TRUONG DEFENDANTS.

The opinion of the court was delivered by: Judge: Garland E. Burrell

STIPULATION AND [PROPOSED] ORDER

Date: December 10, 2010 , Time:9:00 a.m.

GARY TRUONG, and RAYMOND PABLO , Jr. RAMOS,

IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendants, VI TRUONG, aka Ken Vi Truong, GARY TRUONG, and RAYMOND PABLO RAMOS, through their respective attorneys, that the Court should vacate the status conference scheduled for December 10, 2010, at 9:00 a.m., and reset it for February 18, 2011, at 9:00 a.m.

Counsel for defendants require further time to review discovery and to negotiate with the government in an effort to resolve this matter.

It is further stipulated by the parties that the Court should exclude the period from the date of this order through February 18, 2011, when it computes the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act. The parties stipulate that the ends of justice served by granting defendants' request for a continuance outweigh the best interest of the public and the defendants' in a speedy trial, and that this is an appropriate exclusion of time for defense preparation within the meaning of 18 U.S.C. § 3161(h)(7)(A) and (B) (Local Code T4).

Dated: December 7, 2010 Respectfully submitted,

DANIEL BRODERICK Federal Defender /s/ M. Petrik MICHAEL PETRIK, Jr. Assistant Federal Defender Attorneys for Defendant Dated: December 7, 2010 /s/ M. Petrik for Douglas Horngrad DOUGLAS HORNGRAD Attorney for VI TRUONG Dated: December 7, 2010 BENJAMIN B. WAGNER United States Attorney /s/ M. Petrik for Jason Hitt JASON HITT Assistant U.S. Attorney

ORDER IT IS SO ORDERED. The Court orders time excluded from the date of this order through the status conference on February 18, 2011, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B) (Local CodeT4).

GARLAND E. BURRELL, JR. United States District Judge

Stipulation and Order -2- No. 2:09-421 GEB

20101208

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