August 21, 2013
UNITED STATES OF AMERICA, Plaintiff,
HUNG PHAM, Defendant.
DINA L. SANTOS, Bar #204200, A Professional Law Corporation, Sacramento, California, Attorney for Defendant, Hung Pham.
TODD LERAS, Assistant United States Attorney, Attorney for Plaintiff.
STIPULATION AND ORDER VACATING DATE, CONTINUING CASE, AND EXCLUDING TIME
MORRISON C. ENGLAND, Jr., 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 22, 2013, be vacated and the matter be continued to this Court's criminal calendar on August 29, 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 Counsel to review some final changes contained within the proposed plea agreement and to meet with Mr. Pham regarding those changes.
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 29, 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, the status conference scheduled for August 22, 2013, is vacated and continued to August 29, 2013, at 9:00 a.m. in Courtroom 7. August 22, 2013, until August 29, 2013, is excluded under Local Code T4 for the reasons stated in the stipulation. of justice served by granting the requested continuance outweigh the best interests of the public and the defendant in a speedy trial.
IT IS SO ORDERED.