IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
February 28, 2012
UNITED STATES OF AMERICA,
OLIVER P. KIM,
Kenneth L. Rosenfeld, SBN 186060 1000 G Street, Suite 240 Sacramento, California 95814 Telephone: (916) 447-2070 Facsimile: (916) 447-2097 E-mail: email@example.com Attorney for Defendant Oliver P. Kim
THE ROSENFELD LAW FIRM
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
The parties request that the status conference in this case be continued from March 5, 2012 at 9:30 a.m. to May 14, 2012 at 9:30 a.m.. They stipulate that the time between March 5, 2012, and May 14, 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 consult with experts and meet with his client; complete estate matters following the death of counsel's mother in New York; then prepare for and complete trial in a child homicide case in the Sacramento Superior Court. Additionally, AUSA Kyle Reardon will be preparing for, and engaging in trial in a complex matter from approximately mid-April to the week of May 7, 2012.
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).