The opinion of the court was delivered by: Judge: Hon. William B. Shubb
DANIEL J. BRODERICK, Bar# 89424 Federal Defender MATTHEW M. SCOBLE, Bar# 237432 Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone (916) 498-5700 Attorney for Defendant JAMES BERGHUIS
STIPULATION AND [PROPOSED]
ORDER CONTINUING STATUS
DATE: January 9, 2012 TIME: 9:30 a.m.
It is hereby stipulated and agreed to between the United States of America through CAMIL SKIPPER Assistant U.S. Attorney, and defendant, JAMES BERGHUIS by and through his counsel, MATTHEW M. SCOBLE Assistant Federal Defender, that the status conference set for Monday, November 7,2011, be continued to Monday, January 9, 2012, at 9:30 a.m.. The reason for this continuance is to allow defense counsel additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case. This is a complex case with thousands of pages of discovery, comprised largely of financial records. The defense is actively trying to organize these materials and associate them with the relevant charges. Ultimately, this endeavor may require a forensic accountant, however, such services cannot be obtained until the defense has adequately prepared and investigated the case.
Speedy trial time is to be excluded from the date of this order through the date of the status conference set for January 9, 2012, pursuant to 18 U.S.C. §§ 3161 (h)(8)(B)(iv) [reasonable time to prepare] (Local Code T4).
IT IS HEREBY ORDERED that this matter is continued to Monday, January 9, 2012, at 9:30 a.m., for further status conference.
IT IS FURTHER ORDERED that pursuant to 18 U.S.C. §3161 (h)(7)(A) and (B)(iv) and Local Code T4, the period from the date of this stipulation, November 4, 2011, up to and including January 9, 2012, is excluded from the time computations required by the Speedy Trial Act due to ongoing preparation of counsel, and that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial.
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