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United States of America v. Phillip Jacob Shinen

September 20, 2012

UNITED STATES OF AMERICA, PLAINTIFF,
v.
PHILLIP JACOB SHINEN, DEFENDANT,



The opinion of the court was delivered by: Dennis L. Beck United States Magistrate Judge

STIPULATION TO CONTINUE STATUS CONFERENCE; FINDINGS AND ORDER DATE: November 26, 2012 TIME: 1:00 P.M. JUDGE: Hon. Dennis L. Beck

STIPULATION

The United States of America, by and through its counsel of record, and defendant, by and

through his counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on September 24, 2012 at 1:00 p.m.

2. By this stipulation, defendant now moves to continue the status conference until November 26, 2012 at 1:00 p.m. before Magistrate Judge Dennis L. Beck, and to exclude time between the date of this stipulation and November 26, 2012 under 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv). The government does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery associated with this case includes over 4,000 pages of discovery, including investigative reports, bank records and related documents.

All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. Counsel for defendant desires additional time in preparation of this case. The government has provided initial as well as supplemental discovery of several thousand pages.

Defense counsel needs additional time to review discovery with the client, access the discovery for needed motions and investigation, and time to further prepare the case. Defense counsel also has three federal cases set for Monday, September 24, 2012 in Los Angeles, all of which involve multiple defendants and co-counsel which require his appearance.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the ...


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