DAVID D. FISCHER (SBN 224900), LAW OFFICES OF DAVID D. FISCHER, APC, Sacramento, CA, Attorney for Defendant, NEMESSIS ROSENDO VENEGAS.
MICHAEL PETRIK, Attorney for Defendant, EDILIO NAVARRO.
BENJAMIN B. WAGNER, U.S. ATTORNEY, SAMUEL WONG, Assistant U.S. Attorney, Attorney for Plaintiff.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
Plaintiff United States of America, by and through its counsel of record, and the defendants, by and through each counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on July 11, 2013.
2. By this stipulation, the defendants now move to continue the status conference until August 15, 2013, at 9:30 a.m. and to exclude time between July 11, 2013, and August 15, 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 initially provided 32 pages of investigative reports. These reports show that there are additional audio and video recordings and other evidence available for inspection and copying. The government has recently provided some of the discovery that the defense counsel for Mr. Venegas requested. There are some additional items that the Government is working on providing to the defense. The Government is going to need time to provide those items and the defense will need additional time to review everything.
b. Counsel for the defendants desires additional time to consult with their respective clients, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with their clients, to prepare pretrial motions, and to otherwise prepare for trial.
c. Counsel for the defendants believe that 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.
d. The government does not object to the continuance.
e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendants in a trial within the ...