DINA L. SANTOS, A Professional Law Corporation, Sacramento, California, Attorney for Defendant Hung Pham.
DINA L. SANTOS, Attorney for Hung Pham
TODD LERAS, Assistant United States Attorney, Attorney for Plaintiff.
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
MORRISON C. ENGLAND, Chief District Judge.
IT IS HEREBY STIPULATED by and between Assistant United States Attorney Todd Leras, Counsel for Plaintiff, and Attorney Dina L. Santos, Counsel for Defendant Hung Pham; that the status conference scheduled for August 1, 2013, be vacated and the matter be continued to this Court's criminal calendar on August 22, 2013, at 9:00 a.m. for further status and possible change of plea.
This continuance is requested by the defense in order to permit further negotiations and investigation regarding role in the offense which will affect the agreed upon guideline level in the plea agreement. The parties are close to resolution but some final details need to be worked out before the case can resolve.
IT IS FURTHER STIPULATED that time for trial under the Speedy Trial Act, 18 U.S.C. § 3161 et. seq. be tolled pursuant to § 3161(h)(7)(A) & (B)(iv), Local code T-4 (time to prepare), and that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial.
The Court is advised that all counsel have conferred about this request, that they have agreed to the August 22, 2013 date, and that Mr. Leras has authorized Ms. Santos to sign this stipulation on his behalf.
IT IS SO STIPULATED.
Pursuant to the parties' stipulation and good cause appearing therefrom, IT IS SO FOUND and ORDERED. The Court finds that the ends of justice served in granting the continuance and allowing the defendant further time to prepare outweigh the best interests of the public and the defendant in a speedy trial. The status conference currently scheduled for ...