ANNE C. BELES (Cal. Bar No. 200276), ROBERT J. BELES (Cal. Bar No. 41993), Oakland, California, Attorneys for Defendant RUSSELL PATRICK PFIESTER.
ANDREW SUIAN HUANG, Assistant U.S. Attorney.
MELINDA HAAG, United States Attorney.
STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE
YVONNE GONZALEZ ROGERS, District Judge.
Defendant RUSSELL PATRICK PFIESTER, by and through his counsel undersigned and the United States of America, through Assistant United States Attorney ANDREW SUIAN HUANG, hereby stipulate and respectfully request that the Court vacate the Status Conference hearing in the above captioned case, currently set for Thursday, July 11, 2013 at 02:00 p.m., and reset it for the specially set criminal calendar on Thursday, August 22, 2013, at 09:30 a.m.
Counsel for the defendant has previously inquired about scheduling an appointment to review the forensic discovery produced by the government in this matter, but the forensic laboratory is unable to accommodate that request until Thursday, July 11, 2013. Defense counsel, therefore, requires additional time to review said discovery in order to assess the stance of the case and to further investigate the charges filed by the Government.
The parties further stipulate and agree that the time between Thursday, July 11, 2013 and Thursday, August 22, 2013, should be excluded from computation of the time for commencement of trial under the Speedy Trial Act.
The parties stipulate that the ends of justice are served by the Court excluding such time as to allow defense counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161 (h) (7) (B) (iv).
For these reasons, the defendant, defense counsel, and the government stipulate and agree that the interests of justice served by vacating the Status Conference hearing currently set for Thursday, July 11, 2013 at 02:00 p.m. and resetting it for Thursday, August 22, 2013, at 09:30 a.m. outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161 (h) (7) (B) (iv); 18 U.S.C. § 3161 (h) (7) (B) (ii).
IT IS SO STIPULATED.
IT IS SO ...