IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
November 8, 2011
UNITED STATES OF AMERICA,
OLIVER P. KIM,
Kenneth L. Rosenfeld, SBN 186060 THE ROSENFELD LAW FIRM 1000 G Street, Suite 240 Sacramento, California 95814 Telephone: (916) 447-2070 Facsimile: (916) 447-2097 E-mail: firstname.lastname@example.org Attorney for Defendant Oliver P. Kim
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from November 14, 2011 to January 30, 2012 at 9:30 a.m. They stipulate that the time between November 14, 2011 and January 30, 2012 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 discovery and to consult with experts regarding the computer and other evidence.
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).