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United States v. Khan

United States District Court, Ninth Circuit

October 24, 2013

UNITED STATES OF AMERICA, Plaintiff,
v.
MOHAMMAD NAWAZ KHAN, et al., Defendants.

LAW OFFICES OF CHRIS COSCA CHRIS COSCA (SBN 144546) Sacramento, CA, Attorney for Defendant KEWAL SINGH

JOHN VIRGA, Counsel for Defendant Mohammad Nawaz Khan

RON PETERS, Counsel for Defendant Mohammad Adnan Khan

OLAF HEDBERG, Counsel for Defendant Mohammad Shahbaz Khan

KELLY BABINEAU, Counsel for Defendant Iqila Begum Khan

CHRIS COSCA, Counsel for Defendant Kewal Singh

CANDACE FRY, Counsel for Defendant Gurdev Johl

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

MORRISON C. ENGLAND, Jr., Chief District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsel of record, hereby stipulate as follows:

1. The Court previously continued this matter to October 24, 2013, pursuant to a stipulation by the parties.

2. By this stipulation, defendants now move to continue the status conference until November 14, 2013 and to exclude time between October 24, 2013 and November 14, 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 produced over 7, 000 pages of discovery to date, which includes FBI-302s, interview memoranda, the search warrants and affidavit, redacted transcripts of recorded conversations and telephone calls, business records from the Employment Development Department, and deposition transcripts from the prior civil case. The government has also made available for inspection and copying at the FBI evidence seized pursuant to the search warrants and business records that were subpoenaed from various banks. Finally, the government has made available for inspection and copying additional business records from the Employment Development Department. These records are voluminous.

b. Counsel for defendants desire additional time to review and copy discovery for this matter and to conduct additional investigation. In addition, the availability of the Punjabi interpreter is causing logistical difficulties for defense counsel's ability to consult with ...


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