The opinion of the court was delivered by: John A. Mendez United States District Court Judge
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 firstname.lastname@example.org Attorney for Defendant VI A. LE
STIPULATION AND ORDER CONTINUING STATUS
CONFERENCE Date: January 17, 2012 Time: 9:30 a.m.
Judge: Honorable John A. Mendez
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Todd D. Leras, Assistant United States Attorney, together with counsel for defendant Vi A. Le, John R. Manning, Esq., counsel for defendant Tony Sek Mun, Douglas J. Beevers, Esq., and counsel for defendant Dong Ping Huang, Olaf W. Hedberg, Esq., that the status conference presently set for November 1, 2011 be continued to January 17, 2012, at 9:30 a.m., thus vacating the presently set status conference.
The defendants speak Cantonese and require the services of an interpreter in order to communicate effectively with counsel. The Government has provided counsel for the defendants a preliminary framework intended to serve as the basis of future written plea agreements in this matter. Counsels for the defendants need additional time to meet with the defendants (with the interpreter) in order to review the discovery; investigations reports; and, discuss USSG calculations. Counsel for the defendants believes this continuance is necessary in order to effectively communicate the terms of any proposed settlement; its consequences; and, to answer questions by the defendants on how to proceed.
Therefore, counsel for the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the defendants and the public in a speedy trial. 18 U.S.C. 3161(h)(7)(A) (continuity of counsel/ reasonable time for effective preparation) and Local Code T4, and agree to exclude time from the date of the filing of the order until the date of the status conference, January 17, 2012.
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW 1111 H Street, # 204 Sacramento, CA. 95814 (916) 444-3994 Fax (916) 447-0931 email@example.com
Attorney for Defendant VI A. LE
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. VI A. LE, et al., Defendants.
ORDER TO CONTINUE STATUS CONFERNCE GOOD CAUSE APPEARING, it is hereby ordered that the November 1, 2011 status conference be continued to January 17, 2012 at 9:30 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. 3161(h)(7)(A) and Local Code T4 from the date of this order to January 17, 2012.