The opinion of the court was delivered by: Hon. Morrison C. England
Cristina C. Arguedas (CSB 87787) Daniel C. Roth (CSB 270569) ARGUEDAS, CASSMAN & HEADLEY LLP 803 Hearst Avenue Berkeley, CA 94710 Telephone: (510) 845-3000 Facsimile: (510) 845-3003 Attorneys for Sohail Amin
AMDENDED STIPULATION AND ORDER RESETTING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
Time: 9:00 a.m. Courtroom 7
IT IS HEREBY STIPULATED BY AND AMONG ALL PARTIES that the
November 10, 2011 Status Conference previously continued to January 19, 2012, at 9:00 a.m., be set for February 2, 2012, in the same courtroom, and that the time beginning November 10, 2011, and extending through February 2, 2012, should be excluded from the calculation of time under the Speedy Trial Act. The parties submit that the interests of justice are served by the exclusion of time, which will the government additional time to provide relevant discovery and give defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
18 USC 3161(h)(7)(a) and (b)(iv) and Local T4. Michael M. Beckwith, Assistant U.S. Attorney, and Cristina C. Arguedas, Attorney for Defendant Sohail Amin, agree to this continuance.
Defendant has in the past two weeks received twelve CD-ROM discs containing discovery, with additional discovery materials still forthcoming. As such, defense counsel defendant will need more time to prepare, which will include reviewing discovery, discussing that discovery with the defendant, considering new evidence that may affect the disposition of the case, conducting necessary legal research and investigation, and then discussing with the defendant how to proceed. 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. See 18 USC 3161(h)(7)(a) and (b)(iv) and Local T4 (reasonable time for preparation of counsel).
MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE
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