LINDA M. PARISI, LAW OFFICES OF WING & PARISI, Sacramento, CA, Attorney for Charles Connor.
MATTHEW C. BOCKMON, Assistant Federal Defender, Attorney for Defendant STACEY MISTLER.
BENJAMIN B. WAGNER United States Attorney.
OLUSERE OLOWOYEYE, Assistant U.S. Attorney, Attorney for Plaintiff.
AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
Defendant Charles Connor, by and through Linda M. Parisi, his counsel of record, Defendant Stacey Mistler by and through her counsel of record, Matthew Bockmon, and plaintiff, by and through its counsel, Olusere Olowoyeye hereby stipulate as follows:
1. By previous order, this matter was set for status on October 17, 2013.
2. By this stipulation, the defendants now moves to continue the status conference until December 5, 2013, at 9:30 a.m. and to exclude time between October 17, 2013 and December 5, 2013 under Local Code T4. The United States does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. The United States has represented that the discovery associated with this case includes investigative reports and related documents.
b. Counsel for Mr. Connor and Ms. Mistler need additional time to consult, to review discovery, and to discuss potential resolutions, including setting the matter for trial.
c. Counsel for defendants Mr. Connor and Ms. Mistler believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
d. The United States Attorney agrees to ...