BENJAMIN B. WAGNER United States Attorney MICHAEL M. BECKWITH Assistant U.S. Attorney 501 "I" Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2797
STIPULATION AND [PROPOSED] ORDER
RESETTING STATUS CONFERENCE,
AND EXCLUDING TIME UNDER
THE SPEEDY TRIAL ACT
The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Michael M. Beckwith, Assistant United States Attorney, and defendant Jai Hiten Patel, through his counsel of record, Jesse Garcia, Esq., hereby stipulate and agree that the status conference set for June 20, 2011, be continued to August 8, 2011, at 8:30 a.m.
The parties need additional time for preparation. Therefore, the parties have agreed and respectfully request that the Court set the date of August 8, 2011 at 8:30 a.m., for the status conference.
Accordingly, the parties stipulate that time be excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(ii) and (iv) and Local Code T4, to give the defendant time to further review the discovery and to adequately prepare IT IS SO STIPULATED.
UPON GOOD CAUSE SHOWN and by stipulation of all parties, it is hereby ordered that the status conference set for June 20, 2011, at 8:30 a.m., be continued to Monday, August 8, 2011, at 8:30 a.m., and that the time beginning April 18, 2011, extending through and including August 8, 2011, be excluded from the calculation of time under the Speedy Trial Act. The Court finds that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
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