SCOTT N. CAMERON (SBN 226605), Attorney at Law, Sacramento, CA, Attorney for: DERRICK DAVIS.
JASON HITT, Assistant United States Attorney,
MICHAEL BIGELOW, Counsel for GILBERT ARREAZOLA.
STIPULATION REGARDING 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, defendant DERRICK DAVIS, by and through his counsel of record, Scott N. Cameron, and GILBERT ARREAZOLA, by and through his counsel of record, MICHAEL BIGELOW, hereby stipulate as follows:
1. By previous order, this matter was set for status on May 30, 2013, at 9:30 a.m.
2. By this stipulation, defendants now move to continue the status conference until July 11, 2013, at 9:30 a.m., and to exclude time between May 30, 2013, and July 11, 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 discovery to the defense in this case which consists of 292 pages of written or photographic material and 9 compact disks of recorded audio materials.
b. Discovery pages 201-292 were discovered to the defense on May 10, 2013, in compliance with the informal discovery request of the defense. These recently discovered documents will be the basis of additional legal research and investigation by the defense.
c. Respective counsel for each defendant desires additional time to review the document and audio file discovery, consult with their client regarding the discovery, conduct investigation, and to discuss potential resolution with their client and the government.
d. Counsel for each defendant believes that failure to grant the above-requested continuance would deny defendants the reasonable time necessary for effective preparation, ...