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United States v. Romaniolis

United States District Court, Ninth Circuit

August 29, 2013

UNITED STATES OF AMERICA, Plaintiff,
v.
ALEXANDER ROMANIOLIS, Defendant.

JOHN R. MANNING, (SBN 220874) ATTORNEY AT LAW, Sacramento, CA. Attorney for Defendant, Alexander Romaniolis.

Benjamin B. Wagner, JEAN M. HOBLER, Assistant U.S. Attorney United States Attorney.

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER

TROY L. NUNLEY, District Judge.

The United States of America through its undersigned counsel, Jean M. Hobler, Assistant United States Attorney, together with counsel for defendant Alexander Romaniolis, John R. Manning, Esq., hereby stipulate the following:

1. By previous order, this matter was set for status conference on August 29, 2013.

2. By this stipulation, defendants now move to continue status conference until September 19, 2013 and to exclude time between August 29, 2013 and September 19, 2013 under the Local CodeT-4 (to allow defense counsel time to prepare).

3. The parties agree and stipulate, and request the Court find the following:

a. Counsel for Alexander Romaniolis was appointed to represent the defendant on May 9, 2013 and previously appointed council was relieved.
b. This case currently contains 1940 pages of discovery as well as approximately 600 recorded phone calls. (The Government has further represented they have 4 bankers boxes of documents related to the transactions subject to this litigation at their office.)
c. Counsel for the defendant needs additional time to review the discovery, conduct investigation, and interview potential witnesses.
d. Defendant is currently housed at the Sacramento County Jail. Counsel needs additional time to meet with defendant to review the discovery and discuss the case.
e. Counsel for defendant believes the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
f. The Government does not object to the continuance.
g. Based on the above-stated findings, the ends of justice served by granting the requested continuance outweigh the best interests of the public and the defendant in a speedy trial within the original date prescribed by the Speedy Trial Act.
h. For the purpose of computing time under the Speedy Trial Act, 18 United States Code Section 3161(h)(7)(A) and (B)(iv) within which trial must commence, the time period of August 29, 2013 to September 19, 2013, inclusive, is deemed excludable pursuant to 18 United States Code Section 3161(h)(7)(A) and (B)(iv), corresponding to Local Code T-4 because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

IT IS SO STIPULATED.

ORDER

IT IS SO FOUND AND ORDERED.


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