May 21, 2013
UNITED STATES OF AMERICA, Plaintiff,
ANITA SHARMA, et al, Defendant.
MICHAEL CHASTAINE, State Bar #121209 THE CHASTAINE LAW OFFICE, Gold River, CA, Attorneys for Defendant Anita Sharma.
DWIGHT SAMUEL, Attorney for Surjit Singh.
ERIK BABOCK, Attorney for Rajeshwar Singh.
BENJAMIN B. WAGNER, United States Attorney.
LEE BICKLEY, Assistant U.S. Attorney.
STIPULATION AND ORDER CONTINUING STATUS CONFERNCE
TROY L. NUNLEY, District Judge.
It is hereby stipulated between the parties, Lee Bickley, Assistant United States Attorney, Michael Chastaine, attorney for Anita Sharma, Dwight Samuel attorney for Surjit Singh and Erik Babock attorney for Rajeshwar Singh, that the status conference date of Thursday, May 23, 2013 should be continued until Thursday July 11, 2013. The continuance is necessary as defense counsel needs additional time to review discovery (approximately 5889 pages) and consult with their clients regarding possible defenses and options. Counsel for defendants believes that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The government does not object to the continuance.
Further, that some or all of the defense counsel are negotiating with the Government in an attempt to reach a resolution in the matter.
IT IS FURTHER STIPULATED that the period of time from the May 23, 2013 up to and including July 11, 2013 be excluded in computing the time within which the trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(7) and Local Code T4, for ongoing preparation of counsel. It is further stipulated that the need for a continuance and continued counsel preparation outweighs the interests of the public and the defendant in a speedy trial. It is further stipulated that the ends of justice served by continuing this case as requested by the defendants outweigh the interests of the public and the defendants in a speedy trial.
GOOD CAUSE APPEARING, in that it is the stipulation of the parties:
IT IS HEREBY ORDERED that the status conference scheduled for Thursday, May 23, 2013 at 9:30 a.m. be continued to Thursday, July 11, 2013 at 9:30 a.m. and that the period from May 23, 2013 to July 11, 2013 is excludable from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(8)(A) and local rule T4. Further, the ends of justice served by continuing this case as requested due to continued counsel preparation outweigh the interests of the public and the defendants in a speedy trial.