IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
April 19, 2011
UNITED STATES OF AMERICA,
KHAMALE KEOVILAY AND RODNEY SHEAD,
The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge
Scott N. Cameron (SBN 226605) Attorney at Law 1007 7th Street, Suite 319 Sacramento, CA 95814 Telephone: 916-442-5230 Attorney for: RODNEY SHEAD
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME
DATE: April 22, 2011
TIME: 9:00 a.m.
COURT: Hon. Garland E. Burrell, Jr.
Stipulation The parties, through undersigned counsel, stipulate that the status conference, scheduled for April 22, 2011, may be continued to June 24, 2011, at 9:00 a.m. Defendant KEOVILAY has a second case, 09-CR-222 GEB, which is also set for status conference on June 24, 2011. The parties would like to have these cases set for status on the same date. In addition, the instant case involves voluminous wire-tap and video surveillance evidence. The defense is reviewing discovery and investigation is ongoing. As a result, the defense needs additional time before a meaningful status conference can be held. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. The parties also agree that time may be excluded from the speedy trial calculation under the Speedy Trial Act for counsel preparation, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4.
The parties have authorized the defense counsel for Rodney Shead to sign this stipulation on their behalf.
Good cause appearing,
The status conference, scheduled for April 22, 2011, is continued to June 24, 2011, at 9:00 a.m.
Time is excluded from the speedy trial calculation pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 for counsel preparation.
IT IS SO ORDERED.
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