STEVEN G. KALAR, Federal Public Defender, DIANA A. GARRIDO, Assistant Federal Public Defender, San Jose, CA, Counsel for Defendant QUENTIN CHIANG.
STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING DATE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
EDWARD J. DAVILA, District Judge.
The defendant, QUENTIN CHIANG, represented by Assistant Federal Public Defender Diana A. Garrido, and the government, represented by Special Assistant United States Attorney Edward Fluet, hereby stipulate that, with the Court's approval, the status conference currently set for Monday, June 10, 2013 at 1:30 p.m., shall be continued to Wednesday, June 19, 2013 at 1:30 p.m.
The continuance is requested to provide both defense counsel and the government with additional time to review discovery and to negotiate an appropriate resolution. The continuance would provide both parties with the reasonable time necessary for effective preparation. Accordingly, both parties respectfully request that the time between June 10, 2013 and June 19, 2013 be excluded under the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).
Pursuant to agreement and stipulation of the parties, the Court HEREBY ORDERS that the status conference be continued from June 10, 2013 to June 19, 2013. The Court FURTHER ORDERS that the time between June 10, 2013 and June 19, 2013 is excluded under the Speedy Trial Act, 18 U.S.C. §3161. The Court finds, pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), that the failure to grant the requested continuance would unreasonably deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Furthermore, the Court finds that the ends of justice served by granting the requested continuance outweigh the best ...