STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE TIME: 9:30 a.m. JUDGE: Hon. William B. Shubb
It is hereby stipulated and agreed to between the United States of America through TODD PICKELS 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, January 9,2012, be continued to Monday, February 6,2012, 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 was recently notified by the Defendant's tax attorney, Steven Mopsick, that a number of documents had been received that would be relevant to the Defendant's criminal case. Mr. Mopsick will be providing those documents to the defense, forthwith. The Defense did not anticipate this, and needs the additional time to review these new materials.
Speedy trial time is to be excluded from the date of this order through the date of the status conference set for February 6, 2012, pursuant to 18 U.S.C. §§ 3161 (h)(8)(B)(iv) [reasonable time to prepare] (Local Code T4).
DATED: January 4, 2012 Respectfully submitted, DANIEL J. BRODERICK Federal Defender /s/ Matthew M. Scoble MATTHEW M. SCOBLE Assistant Federal Defender Attorney for Defendant JAMES BERGHUIS DATED: January 4, 2012 BENJAMIN B. WAGNER United States Attorney /s/ Matthew M. Scoble for: TODD PICKLES Assistant U.S. Attorney Attorney for Plaintiff
IT IS HEREBY ORDERED that this matter is continued to Monday, February 6, 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, January 4, 2012, up to and including February 6, 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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