MELINDA HAAG (CABN 132612), United States Attorney, J. DOUGLAS WILSON (DCBN 412811), Chief, Criminal Division, STACEY P. GEIS (CABN 181444), Assistant United States Attorney, San Francisco, California, Attorneys for United States of America.
STIPULATION AND ORDER TO CONTINUE TRIAL DATE
CHARLES R. BREYER, District Judge.
With the agreement of the parties, and the consent of the defendants, CHOU VANG, VANG PAO YANG, and PAO VANG ("defendants"), the parties hereby request the Court to continue the trial in this matter from November 18, 2013, to March 10, 2014.
1. This case was indicted on October 11, 2011. Since then the government has produced discovery and responded to a motion to compel discovery. The parties have also spent considerable time discussing a possible resolution. Most recently, those discussions were renewed in light of guidance regarding drug cases recently issued by the Department of Justice.
2. The case is currently scheduled to go to trial in 4 weeks, on November 18, 2013. The parties would like additional time to discuss a possible global resolution. To that end, the parties are requesting a continuance.
3. Government counsel spoke with the Court's clerk on October 17 and again on October 18, 2013, who stated that the Court's criminal trial calendar is available for trial on March 10, 2014. That date is available for all parties.
4. This request is the first request for a continuance by the parties.
5. Should the Court grant a continuance of the trial until March 11, 2014, the parties would offer the following pretrial conference and jury selection schedule:
6. The parties would agree to an exclusion of time from November 18, 2013, until March 10, 2014, in order to allow for effective preparation and continuity of counsel, pursuant to Title 18 U.S.C. § 3161(h)(7)(B)(iv).
7. The parties, with the consent of the defendants, would request that the Court order: 1) the November 18, 2013, trial date and the November 12, 2013, pretrial conference dates be vacated; 2) a new trial date be scheduled for March 10, 2014; and 3) the period from November 18, 2013, until March 10, 2014, be excluded pursuant to Title 18 U.S.C. § 3161(h)(7)(B)(iv).
IT IS SO STIPULATED.
8. GOOD CAUSE HAVING BEEN SHOWN, by the request of the parties, and, with the consent of the defendants, the Court orders: 1) the November 18, 2013, trial date and the November 12, 2013, pretrial conference dates be vacated; 2) a new trial date be scheduled for March 10, 2014, with a pretrial conference scheduled for March 4, 2014; and 3) the period from ...