TTim A. Pori (SBN 189270) John F. Baumgardner (SBN 275674) LAW OFFICES OF TIM A. PORI, Vallejo, CA, Attorneys for Defendant MYRON JACOBS
DAVID FISCHER, Attorney for Defendant STACEY JACOBS
LEE S. BICKLEY, Assistant United States Attorney.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
MORRISON C. ENGLAND, Jr, District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendants MYRON JACOBS and STACEY JACOBS, by and through their counsels of record, hereby stipulate as follows:
1) By previous order, this matter was set for status on August 29, 2013 at
2) By this stipulation, defendants now move to continue the status conference until September 26, 2013 at 9:00 a.m. and to exclude time between August 29, 2013, and September 26, 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 has represented that the discovery associated with this case includes, to date, 4, 423 pages of investigative reports and related documents in electronic form. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b) Counsel for defendants desire additional time to consult with their respective clients, to review the current charges, to conduct investigation and research related to the charges, and to review discovery for this matter.
c) Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, ...