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United States of America v. Gary Jason Grant

February 18, 2011

UNITED STATES OF AMERICA PLAINTIFF,
v.
GARY JASON GRANT, ET. AL., DEFENDANT



The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE DATE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT

DATE:February 18, 2011 TIME: 9:00 a.m. JUDGE: Hon. Garland Burrell

It is hereby stipulated and agreed to between the United States of America through Samuel Wong, Assistant U.S. Attorney, and the defendants, Gary Jason Grant, Timothy Thomas Seaver, and Michael Christopher Moore by and through their respective attorneys, that: (1) the presently set February 18, 2011, status conference shall be continued to April 8, 2011 at 9:00 a.m.; and (2) time from the date of the parties' stipulation, February 16, 2011 through and including, April 8, 2011, shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. section 3161(h)(7)(A) and (B)(ii) and (iv) and Local Codes T2 (complex and unusual case) and T4 (reasonable time for defense counsel to prepare).

The parties note that this case stems from the earlier investigation and prosecution of Daren Glosser and Shannon Selle, Case No. CRS 05-309 GEB, which this Court previously determined to be complex and unusual within the meaning of the Speedy Trial Act based on the grounds that the conspiracy charge spans almost four years and the case involves approximately 22 search warrants, hundreds of exhibits, numerous witnesses, and multiple law enforcement agencies. Consequently, in the instant case, the United States has produced substantial voluminous discovery consisting of thousands of documents to defense counsel and they will need additional time to review the discovery, investigate the facts, and conduct legal research regarding possible defenses.

Based on these facts, the parties stipulate and agree that the instant case is unusual and complex and it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in section 3161. In addition, the parties stipulate and agree that the trial delay and exclusion of time requested herein is necessary to provide defense counsel reasonable time to prepare their respective clients' defenses taking into account due diligence.

DATED: February 17, 2011

Respectfully submitted,

Preeti Bajwa PREETI K.BAJWA

Attorney for Defendant

GARY JASON GRANT

DATED: February 17, 2011

Respectfully submitted,

Dan Frank Koukol DAN ...


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