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United States of America v. Oliver P. Kim

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


September 8, 2011

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
OLIVER P. KIM,
DEFENDANT.

STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME

The parties request that the status conference in this case be continued from September 12, 2011 to November 14, 2011 at 9:00 a.m. They stipulate that the time between September 12, 2011 and November 14, 2011 should be excluded from the calculation of time under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant has reasonable time to review the Government's initial discovery and to obtain the services of an expert to review the computer evidence against the defendant. 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, THE ROSENFELD LAW FIRM DATE: September 9, 2011 By: /s/ Kenneth L. Rosenfeld*fn1 KENNETH L. ROSENFELD Attorney for Defendant DATE: September 9, 2011 /s/ Kyle Reardon KYLE REARDON Assistant United States Attorney

SO ORDERED.


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