Mark Waecker (SBN# 81375), LAW OFFICES OF MARK WAECKER, Los Angeles, CA, Attorney for Defendant, IMESH PERERA.
Jill Thomas, Assistant United States Attorney, Attorney for Plaintiff, UNITED STATES OF AMERICA.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., Chief District Judge.
Defendant Imesh Perera, by and through his undersigned counsel and the United States Government, by and through Assistant United States Attorney Jill Thomas, hereby agree and stipulate that the status conference currently scheduled for December 5, 2013 be continued until January 23, 2013. The defendant is charged in a five count indictment alleging violations of 21 U.S.C. §§s 841 (a) (1) and § 846 - possession with intent to distribute and conspiracy to distribute methamphetamine. The government has previously provided a Plea Agreement to the defendant. It includes a factual basis stretching over a period of more than one year and involving numerous intercepted telephone conversations. The defense has requested the government provide some additional information clarifying relevant aspects as to some of the incidents mentioned in the factual basis. The government has provided this information and the defense needs additional time to review the materials. Just recently the government has agreed to entertain another proposal from the defendants and needs more time to evaluate and respond to the new proposal. The parties therefore agree that additional time is needed to finalize the terms of a plea agreement. Therefore, the parties request a status conference date of January 23, 2013 and that date is available with the Court.
The parties agree that time should be excluded under 18 U.S.C. § 3161 (h) (8) (i) for defense preparation and under local code T4.
Good cause having been shown, it is hereby ordered that the status conference currently scheduled for December 5, 2013, is continued to January 23, 2013 at 9:00 a.m. Based on the representation of the parties, the Court finds that the ends of justice served by granting the continuance outweigh the best interest of the public and the defendant in a speedy trial. Time under the Speedy Trial Act shall ...