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United States of America v. Michael Giang

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


July 14, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
MICHAEL GIANG
DEFENDANT.

The opinion of the court was delivered by: Hon. John A. Mendez U.S. District Judge

BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2770

STIPULATION AND ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from July 19, 2011 to September 20, 2011 at 9:30 a.m. They stipulate that the time between July 19, 2011 and September 20, 2011 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Specifically, defense counsel needs additional time to review the discovery provided by the government, to discuss that discovery with the defendant and to perform investigation. The parties stipulate and agree 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).

Respectfully Submitted,

SO ORDERED.

John A. Mendez

20110714

© 1992-2011 VersusLaw Inc.



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