The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
BENJAMIN B. WAGNER United States Attorney JOHN K. VINCENT MICHAEL D. ANDERSON Assistant U.S. Attorneys 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916)554-2700
STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER SPEEDY TRIAL ACT AND ORDER THEREON
IT IS HEREBY STIPULATED AND AGREED between the defendants, Obed Ur Rahman and Shaker Ahmed, by and through their defense counsel, Randy Thomas and Joseph Wiseman, respectively, and the United States of America by and through its counsel, Assistant U.S. Attorney John Vincent, that the status conference presently set for May 5, 2011 at 9:00 a.m., should be continued to June 9, 2011 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from May 5, 2011 through June 9, 2011.
The reason for the continuance is that the case is a tax and social security fraud case that is somewhat complex. Mr. Thomas has been negotiating a plea agreement on behalf of OBED UR RAHMAN with the government and has provided additional information to the government concerning the social security charges.
The United States will be producing additional discovery to defendant RAHMAN concerning the Social Security fraud counts in the Indictment. Additional time will be needed to complete plea negotiations. Accordingly, the time between May 5, 2011 and June 9, 2011 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Thomas and Mr. Wiseman have authorized Assistant U.S. Attorney Vincent to sign this pleading for them.
For the reasons set forth above, the Court finds that there is GOOD CAUSE for the continuance and the exclusion of time, and that the ends of justice served by this continuance outweigh the best interests of the public and the defendants in a speedy trial. The calendaring change set forth above IS SO ORDERED.
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