DWIGHT M. SAMUEL (CA BAR# 054486), LAW OFFICE OF DWIGHT M. SAMUEL, A PROFESSIONAL CORPORATION, Sacramento, California, Attorney for Defendant, DISHAN PERERA.
JILL THOMAS, Assistant U.S. Attorney, SHARI RUSK, Attorney for Defendant, TOREY MOORE.
Olaf hedberg, Attorney for Defendant, Lonard Woodfork.
CHRIS COSCA, Attorney for Defendant, RAMIRO GARCIA.
DAN KUOKOL, Attorney for Defendant, JASON CAVILEER.
CHRISTOPHER HAYDN-MYER, Attorney for Defendant, LOVE SIDHU
MARK REICHEL Attorney for Defendant NAVJOT SINGH.
STIPULATION AND ORDER
MORRISON C. ENGLAND, Jr., Chief District Judge.
IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Assistant United States Attorney Jill Thomas, and defendant Dishan Perera through his undersigned counsel Dwight Samuel, defendant Torey Moore, through his undersigned counsel Shari Rusk, defendant Lonard Woodfork, through his undersigned counsel Olaf Hedberg, defendant Ramiro Garcia, through his undersigned counsel Chris Cosca, defendant Jason Cavileer, through his undersigned counsel Dan Koukol, defendant Love Sidhu, through his undersigned counsel Christopher Haydn-Myer, and defendant Navjot Singh, through his undersigned counsel Mark Reichel, that the previously scheduled status conference date of December 5, 2013, be vacated and the matter set for status conference on January 23, 2014.
The reason for this request is that counsels are engaged in ongoing negotiations in regarts to immigration issues. Cousels are exchanging supporting documentations in support to this issue. Counsel needs additional time to conduct these negotiations to reach a plea agreement.
The parties further agree and stipulate that the time period from the filing of this stipulation until January 23, 2014, should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4, to allow continuity of counsel and to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. Based on the stipulation of the parties and the recitation of facts contained therein, the Court finds that 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. The Court finds that the ends of justice ...