TIM F. TUITAVUKI SBN212886, LAW OFFICE OF TIM F. TUITAVUKI, STOCKTON, CA, Attorney for Brian Federico.
BRIAN C. LEWIS, Assistant U.S. Attorney,
RUSSELL S. HUMPHREY, Attorney for Kevin Laney.
BRENT FAIRBANKS ROMNEY, Attorney for Miguel Ibarria.
TIM ALLEN PORRI, Attorney for Brandon Hourmouzus.
ROBERT JOSEPH BELES, Attorney Charles Burnett.
STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME
YVONNE GONZALEZ ROGERS, District Judge.
Plaintiff United States of America, by and through its counsel of record, and the defendants, by and through their counsel of record, hereby stipulate as follows:
1. The parties are set to appear on June 12, 2013 at 2:00 p.m. for status. At the status conference on April 11, 2013, I provided a discovery request to Mr. Corrigan for additional information needed to prepare Mr. Federico's defense and the matter was continued to May 2, 2013, by stipulation and order.
2. On May 2, 2013, Assistant United States Attorney, Brian C. Lewis appeared and is now handling this case as former AUSA, Stephen G. Corrigan, retired.
3. On May 24, 2013, I met with Mr. Lewis to discuss this case and the discovery request. Mr. Lewis is in the process of obtaining the records requested. The information requested will not be ready by the date of the status conference scheduled for June 12, 2013. Even if it was received by that date, it is not sufficient time for me to review those documents to be ready to proceed on June 12, 2013.
4. By this stipulation, the defendants now move to continue the status conference until July 25, 2013, and to exclude time between June 12, 2013 to July 25, 2013. The Government does not oppose this request.
5. Counsel for the defendant believes that failure to grant the above requested continuance would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence and ...