BENJAMIN B. WAGNER United States Attorney TODD D. LERAS Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2918
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
IT IS HEREBY STIPULATED between Plaintiff United States of America, by and through Assistant United States Attorney Todd D. Leras, and Attorney Dwight Samuel on behalf of Dishan Perera, Attorney Olaf Hedberg on behalf of Leonard Woodfork, Attorney John Virga on behalf of Navpreet Singh, Attorney Christopher Haydn-Myer on behalf of Lovedeep Sidhu, Attorney Mark Reichel on behalf of Navjot Singh, Attorney Dan Koukol on behalf of Jason Cavileer, Attorney Shari Rusk on behalf of Torey Moore, and Attorney Christopher Cosca on behalf of Ramiro Garcia, that the status conference scheduled for March 7, 2013, be continued to April 4, 2013, at 9:00 a.m.
Attorney Dwight Samuel was recently appointed to represent Dishan Perera in this matter. The government reproduced the voluminous discovery in this wiretap investigation and provided it to Mr. Samuel. He is still reviewing it. Because Dishan Perera's telephone was the subject of various rounds of court-authorized wiretaps in the case, the discovery contains a substantial amount of material relevant to Dwight Samuel's representation of Dishan Perera. In addition, continuing investigation is occurring on behalf of other defendants related to the extent of their participation in the conspiracy alleged in the case. This investigation impacts the potential sentencing guidelines applicable to each of the alleged participants. Given the voluminous discovery, including telephone calls intercepted during the course of three successive rounds of wiretaps, counsel requires additional preparation time. The parties therefore request to continue the status conference to April 4, 2013.
For the above-stated reasons, the parties stipulate that time be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4 (reasonable time to prepare and continuity of counsel). Defense counsel have authorized Assistant U.S. Attorney Todd D. Leras to sign this stipulation on their behalf.
1. A status conference in this matter is set for April 4, 2013, at 9:00 a.m.;
2. Based on the stipulation of the parties, the Court finds that the ends of justice outweigh the best interest of the public and Defendant in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare) up to and including April 4, 2013.
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