BENJAMIN B. WAGNER, United States Attorney, LAUREL J. MONTOYA, Assistant United States Attorneys, Fresno, CA, Attorneys for Plaintiff. ALONZO J. GRADFORD Attorney for Defendant Andy Yung Kwong Chan.
SETH P. CHAZIN, Attorney for Defendant John Zhong Xian Huang.
GEORGE SIDDELL, Attorney for Defendant Chiu Chuen Lau.
DORON WEINBERG, Attorney for Defendant Tony Chao Fan Luo.
KIRK MCALLISTER, Attorney for Defendant Michael Chau.
HARRIS B. TABACK, Attorney for Defendant Yao Ming Yu.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
ANTHONY W. ISHII, Senior 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. By previous order, this matter was set for status on July 8, 2013 at 1:30 p.m.
2. By this stipulation, defendants now move to continue the status conference until October 7, 2013 at 1:30 p.m. and to exclude time between July 8, 2012 and, October 7, 2013 under 18 U.S.C.§ 3161(h)(7)(A), B(iv). Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. The government has represented that the discovery associated with this case includes approximately 508 pages of investigative reports and related documents in electronic form as well as approximately 25 CDs of interviews, photographs and video recordings. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b. Offers have been conveyed, counteroffers have been made, and plea agreements have been prepared as to several of the defendants that the parties felt were reasonably likely to result in the resolution.
c. Counsel for defendants need additional time for investigation and preparation. Counsel for defendants are continuing to investigate the matter, evaluate offers and the potential immigration consequences of a plea. Counsel for defendants believe that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation and resolution, taking into account the exercise of due diligence. The parties continue ...