The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge
BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Suite 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for SHAUN BHAMANI
STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER SPEEDY TRIAL ACT' ORDER THEREON
IT IS HEREBY STIPULATED AND AGREED between the defendants, Akbar Bhamani, Zain Bhamani, Ken Sarna, Aly Bhamani, Feroza Bhamani, Laila Bhamani, Jose Pierre Quintana, and Shaun Bhamani, by and through their undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Steven Lapham, that the status conference presently set for November 17, 2011 at 9:00 a.m., should be continued to February 9, 2012 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from November 17, 2011 through February 9, 2012.
The reason for the continuance is that the defendants are continuing their investigation and Mr. Locke, who was only recently appointed to represent Mr. Shaun Bhamani is, at this time, only half way through the 20,000 pages of discovery and needs the additional time to prepare the case. The parties stipulate that the continuance should be granted for defense preparation pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv).The parties further stipulate that the ends 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). Undersigned counsel have authorized Mr. Locke to sign this pleading for them.
For the reasons stated in the above stipulation, the Court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. The status conference in this matter now set for November 17, 2011 is accordingly continued to February 9, 2012 at 9:00 a.m.
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