JOHN R. MANNING (SBN 220874), ATTORNEY AT LAW, Sacramento, CA, Attorney for Defendant Alexander Romaniolis.
Benjamin B. Wagner, United States Attorney, JEAN M. HOBLER, Assistant U.S. 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 September 19, 2013.
2. By this stipulation, defendants now move to continue status conference until October 24, 2013, at 9:30 a.m., and to exclude time between September 19, 2013 and October 24, 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. Additionally, the Government has 4 bankers boxes of documents related to the transactions at their office. The defense has reviewed some of these documents. However, additional review is necessary and ongoing.
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 ...