IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
August 2, 2012
UNITED STATES OF AMERICA,
EMMA NERSESYAN, ) ET AL., DEFENDANTS.
The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge
DANIEL J. BRODERICK, Bar #89424 Federal Defender DOUGLAS BEEVERS, USVI Bar #766 Assistant Federal Defender Designated Counsel for Service 801 I Street, 3rd Floor Sacramento, California 95814 Telephone: (916) 498-5700 Attorney for Defendant EMMA NERSESYAN
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE Date: September 28, 2012 Time: 9:00 a.m. Judge: Hon. Garland E. Burrell, Jr.
The parties request that the status conference in this case be continued from August 3, 2012, to September 28, 2012 at 9:00 a.m. They stipulate that the time between August 3, 2012 and September 28, 2012 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C §3161(h)(7)(A) and (B)(iv)and Local Code T-4. Defense counsel needs additional time to investigate the facts of the case and to negotiate a resolution to this matter. Specifically, defense counsel needs additional time to review and examine the discovery with their clients. 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) and (B)(iv)and Local Code T-4.
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for August 3, 2012, be continued to September 28, 2012, at 9:00 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the September 28, 2012, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C §3161(h)(7)(A) and (B)(iv) and Local Code T-4.
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