The opinion of the court was delivered by: Judge: Hon. William B. Shubb
DANIEL J. BRODERICK, Bar# 89424 Federal Defender MATTHEW M. SCOBLE, Bar# 237432 Assistant Federal Defender 801 I Street, 3rd Floor Sacramento, California 95814 Telephone (916) 498-5700 Attorney for Defendant JAMES BERGHUIS
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE DATE: March 26, 2012 TIME: 9:30 a.m.
It is hereby stipulated and agreed to between the United States of America through TODD PICKLES 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, March 12, 2012, be continued to Monday, March 26, 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 March 26, 2012, pursuant to 18 U.S.C. §§ 3161 (h)(8)(B)(iv) [reasonable time to prepare] (Local Code T4).
IT IS HEREBY ORDERED that this matter is continued to Monday, March 26, 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, March 9, 2012, up to and including March 26, 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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