BENJAMIN B. WAGNER, United States Attorney, JARED C. DOLAN, Assistant United States Attorney, Sacramento, CA, Attorneys for Plaintiff, United States of America.
JOHN MANNING, Counsel for Defendant Ryan Herbert Smith.
MICHAEL BARRETTE, Counsel for Defendant Rajinder Dhillon II,
SHARI RUSK, Counsel for Defendant Balwinder Khangura.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER THEREON
MORRISON ENGLAND, Jr., District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsel of record, hereby stipulate as follows:
1. The Court previously continued this matter to June 13, 2013 pursuant to a stipulation by the parties.
2. By this stipulation, defendants now move to continue the status conference until July 18, 2013 and to exclude time between June 13, 2013 and July 18, 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 over 7, 000 pages of discovery to date, which includes FBI-302s, interview memoranda, the search warrants and affidavit, redacted transcripts of recorded conversations and telephone calls, business records from the Employment Development Department, and deposition transcripts from the prior civil case. The government has also made available for inspection and copying at the FBI evidence seized pursuant to the search warrants and business records that were subpoenaed from various banks. Finally, the government has made available for inspection and copying additional business records from the Employment Development Department. These records are voluminous.
b. Counsel for defendants desire additional time to review and copy discovery for this matter and to conduct additional investigation. In addition, the availability of the Punjabi interpreter is causing logistical difficulties for defense counsel's ability to consult with their clients and more time is needed to accomplish that consultation.
c. Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, ...