July 10, 2013
UNITED STATES OF AMERICA, Plaintiff,
SURJIT SINGH, RAJESHWAR SINGH, ANITA SHARMA, Defendants.
ERIK BABCOCK, (Cal. 172517), Oakland, CA, Attorney for Defendant.
MICHAEL CHASTAINE, Attorney for Anita Sharma.
DWIGHT SAMUEL, Attorney for Surjit Singh.
BENJAMIN B. WAGNER, United States Attorney.
LEE BICKLEY, Assistant U.S. Attorney.
STIPULATION AND ORDER CONTINUING STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
It is hereby stipulated between the parties, Lee Bickley, Assistant United States Attorney, Michael Chastaine, attorney for Anita Sharma, Dwight Samuel attorney for Surjit Singh, and Erik Babcock attorney for Rajeshwar Singh, that the status conference set for Thursday, July 11, 2013 should be continued until Thursday September 12, 2013 at 9:30 a.m. This continuance is necessary as defense counsel needs additional time in which to review discovery (approximately 6, 000 pages), consult with their clients regarding possible defenses, in conduct necessary investigation. Counsel for defendants believe that the failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
Further, that some or all of the defense counsel are negotiating with the Government in an attempt to reach a resolution in the matter.
IT IS FURTHER STIPULATED that the period of time from July 11, 2013 up to and including September 12, 2013 be excluded in computing the time within which the trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(7) and Local Code T4, for ongoing preparation of counsel. It is further stipulated that the need for a continuance and continued counsel preparation outweighs the interests of the public and the defendant in a speedy trial.
GOOD CAUSE APPEARING, in that it is the stipulation of the parties:
IT IS HEREBY ORDERED that the status conference scheduled for Thursday, July 11, 2013 at 9:30 a.m. be continued to Thursday, September 12, 2013 at 9:30 a.m. and that the period from July 11, 2013 to September 12, 2013 is excludable from calculation under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(8)(A) and local rule T4. Further, that the need for a continuance and continued counsel preparation outweighs the interests of the public and the defendant in a speedy trial.