IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 24, 2012
UNITED STATES OF AMERICA, PLAINTIFF,
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 January 30, 2012 at 9:30 a.m. to March 5, 2012 at 9:30 a.m. They stipulate that the time between January 30, 2012 and March 5, 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. Since the last continuance, defense counsel has been handling complex estate matters following the death of counsel's mother who passed away in New York in mid-December and counsel has therefore been unable to devote adequate time to discovery review and consultation with experts.
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).