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United States of America v. Nina Nguyen

February 21, 2013

UNITED STATES OF AMERICA, PLAINTIFF,
v.
NINA NGUYEN, ET. AL., DEFENDANTS,



The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

STIPULATION

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

NGUYEN, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on February 22, 2013, at 9 a.m.

2. By this stipulation, defendant now moves to continue the status conference until April

5, 2013, and to exclude time between February 22, 2013, and April 5, 2013, under Local Code T4.

Plaintiff does not oppose this request.

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

a. The government has produced approximately 4,844 pages of discovery to the defense.

b. Counsel for defendant desires additional time to review the document discovery, consult with the client regarding the discovery, conduct investigation, and to discuss potential resolution with his client and the government.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny defendant 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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