BENJAMIN B. WAGNER, United States Attorney, R. STEVEN LAPHAM, LEE S. BICKLEY, Assistant United States Attorneys, Sacramento, CA, Attorneys for Plaintiff, United States of America.
Danny D. Brace, Jr., Counsel for Defendant Sergey Shchirskiy.
Chris Haydn-Myer, Counsel for Defendant Anton Tkachev.
Candice L. Fields, Counsel for Defendant Nazhmudin Rustamov.
STIPULATION REGARDING CONINUATION OF STATUS CONFERENCE AND EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendants Sergey Shchirskiy, Anton Tkachev, and Nazhmudin Rustamov, by and through their counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on May 2, 2013 at 9:00 a.m. before Judge Morrison England.
2. By this stipulation, defendants now move to continue the status conference until July 11, 2013, at 9:30 a.m. before Judge Troy Nunley, and to exclude time between May 2, 2013 and July 11, 2013, inclusive, under Local Code T4 (to allow defense counsel time to prepare). Plaintiff 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 1, 500 pages of discovery, including investigative reports and 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 the defendants desire additional time to consult with their clients, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, and to discuss potential resolutions with their clients. Counsel for Mr. Rustamov was appointed in March 2013.
c. Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into ...