Edward W. Swanson, SBN 159859 Britt Evangelist, SBN 260457 SWANSON & McNAMARA LLP 300 Montgomery Street, Suite 1100 San Francisco, California 94104 Telephone: (415) 477-3800 Facsimile: (415) 477-9010 Attorneys for AKBAR BHAMANI
STIPULATION AND ORDER TO VACATE TRIAL SETTING CONFERENCE, TO SET TRIAL DATE AND TRIAL READINESS CONFERENCE, AND TO EXCLUDE TIME
Date: August 23, 2012 Time: 9:00 am Crt Rm.: 7 (MCE)
IT IS HEREBY STIPULATED by defendants AKBAR BHAMANI, through his counsel, Edward W. Swanson; ZAIN BHAMANI, through his counsel, Matthew G. Jacobs; KEN SARNA, through his counsel, Joseph A. Welch; ALY BHAMANI, through his counsel, John Panneton; FEROZA BHAMANI, through her counsel, Matthew C. Bockmon; LAILA BHAMAI, through her counsel Clyde M. Blackmon; JOHN PIERRE QUINTANA, through his counsel, Richard Pachter; and SHAUN BHAMANI, through his counsel, Bruce Locke; and by the United States of America, through its counsel, Assistant U.S. Attorney R. Steven Lapham, that the trial setting conference now scheduled for August 23, 2012 at 9:00 a.m., be vacated and that trial in this matter be set on July 15, 2013. The parties also request that a trial readiness conference be set for Thursday, June 6, 2013 at 9:00 a.m.
The parties stipulate that setting a July 15, 2013 trial date in this case is necessary to allow for the effective preparation and continuation of counsel given the complexity of this multi-defendant action involving tens of thousands of pages of discovery. 18 U.S.C. §§ 3161(h)(7)(B)(ii), 3161(h)(7)(B)(iv). The parties further stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Therefore, the parties stipulate pursuant to 18 U.S.C. § 3161(h)(7)(B)(ii)and(iv) [Local Code T2, T4] that time shall be excluded from August 23, 2012, to June 6, 2013. Undersigned counsel have authorized Mr. Swanson to sign this pleading for them.
ORDER TO VACATE TRIAL SETTING CONFERENCE , TO SET TRIAL DATE AND TRIAL READINESS CONFERENCE AND EXCLUDING TIME
This matter having come before me pursuant to the stipulation of the parties and good cause appearing therefore,
IT IS ORDERED THAT: the trial setting conference now set for August 23, 2012 at 9:00 a.m. is vacated, a trial readiness conference is set for June 6, 2013 at 9:00 a.m. and trial in this matter is set for July 15, 2013.
Further, the Court finds that time is excluded based upon the representation of the parties that the interests of justice outweigh the public interest in a speedy trial, given the need for further defense preparation and the complex nature of the matter. Therefore, such time will be excluded pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(ii)and(iv) [Local Code T2, T4], from August 23, 2012 until the next appearance on June 6, 2013.
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