IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
July 31, 2012
UNITED STATES OF AMERICA, PLAINTIFF,
TOMIKA REED, ET. AL,
The opinion of the court was delivered by: Hon. Garland E. Burrell
CLYDE M. BLACKMON (SBN 36280) ROTHSCHILD WISHEK & SANDS LLP 2 901 F STREET, SUITE 200 Sacramento, CA 95814 3 Telephone: (916) 444-9845 4 Attorneys for Defendant, BUENA MARSHALL 5 6
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE Date: August 3, 2012 Time: 9:00 a.m. Ctrm: 10
IT IS HEEREBY STIPULATED by the United States of America, 17 through its counsel Assistant U. S. Attorney Russell Carlberg, 18 and Temika Reed, through her counsel Timothy Warriner, Buena 19
Marshall, through her counsel Clyde M. Blackmon, Jake Weathers, 20 through his counsel Hayes H. Gable, III, Deborah Loudermilk, 21 through her counsel James T. Reilly, Reginald Dodson, Sr., 22 through his counsel Dina Santos, and Kadesta Harris, through her 23 counsel J. Tony, that the status conference now set for 9:00 24 a.m. on August 3, 2012, may be continued to 9:00 a.m. on 25 September 28, 2012. 26
A continuance of the status conference is requested by 27 defense counsel in order to obtain additional time in which to 28 review almost 10,000 pages of discovery that have been provided 2 by the government thus far in the case and to conduct 3 investigation into various issues pertaining to the defense of 4 the matter. 5
IT IS FURTHER STIPULATED that, pursuant to 18 U.S. C. 6 sections 3161(h)(7)(B)(ii) and 3161(h)(7)(B)(iv), that time 7 should be excluded from August 3, 2012, to September 28, 2012, 8 due to the complexity of the case, as evidenced by the amount of 9 discovery provided by the government and the number of 10 defendants in the matter, and to provide defense counsel more 11 time in which to prepare, taking into account the exercise of 12 due diligence. (Local Codes T2 and T4). The parties also 13 stipulate that a granting of a continuance of the status 14 conference for reasons stated above will serve the ends of 15 justice and outweighs the bests interests of the public and the 16 defendants in a speedy trial. 17
IT IS SO STIPULATED.
Good cause appearing upon stipulation of the parties, the 3 status conference now scheduled for 9:00 a.m. on August 3, 2012, 4 is vacated and the matter is continued for a status conference 5 on September 28, 2012, at 9:00 a.m. 6
Based on the representation of the parties that the case is 7 complex and that additional time is required for adequate 8 preparation by defense counsel, the Court finds that time should 9 be excluded from August 3, 2012, to September 28, 2012, pursuant 10 to 18 U.S.C. sections 3161(h)(7(B)(ii) and 3161(h)(7)(B)(iv) 11 (Local Codes T2 and T4) and that the granting of the continuance 12 of the status conference serves the ends of justice and 13 outweighs the best interests of the public and the defendants in 14 a speedy trial. 15
IT IS SO ORDERED.
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