IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
July 22, 2011
THE UNITED STAES OF AMERICA
JOSE OLIVARA ZAPIEN ET AL.
The Law Office of Olaf W. Hedberg Olaf W. Hedberg, State Bar #151082 901 H St., Suite 673 Sacramento, California 95814 (916) 447-1192 office 1-412-774-3537 faX email@example.com
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from July 25 , 2011 to August 29, 2011 at 8:30 a.m. They stipulate that the time between July 25, 2011 and August 29, 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, all defense counsel need additional time to review the discovery provided and investigate the case. Well over 2000 pages of discovery and 80 CD's containing video, audio recordings and photographs have been provided to the defense counsel to date. Defense counsel are still reviewing approximately 1200 new pages of discovery provided by the government in January 2011. Further, the parties are actively engaged in plea negotiations and it is anticipated this time period will aid in the resolution of this case for a number of the parties. 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. 18 U.S.C. § 3161(h)(7)(A).
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