IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
May 4, 2012
UNITED STATES OF AMERICA,
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: email@example.com 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 May 14, 2012 at 9:30 a.m. to June 11, 2012 at 9:30 a.m.. They stipulate that the time between May 14, 2012, and June 11, 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. Counsel for the defendant is in a child homicide trial in the Sacramento County Superior Court, People v. Harper, case number 09F06535, and the trial is expected to extend at least through the first week of June. Additionally, counsel for the defendant needs reasonable time to complete his consultation with experts and discuss their findings and a possible resolution of the matter with his client.
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).