DAVID D. FISCHER, (SBN 224900) LAW OFFICES OF DAVID D. FISCHER, APC, Sacramento, CA., Attorney for Defendant STACEY JACOBS.
BENJAMIN WAGNER, U.S. ATTORNEY.
LEE BICKLEY, Assistant U.S. Attorney, Attorney for Plaintiff.
DAVID D. FISCHER, Attorney for Defendant, STACEY JACOBS.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
MORRISON C. ENGLAND, Jr., Chief District Judge.
Plaintiff United States of America, by and through its counsel of record, and the defendant, by and through her counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on December 5, 2013.
2. By this stipulation, the defendant now moves to continue the status conference until January 30, 2014, and to exclude time between December 5, 2013, and January 30, 2014, 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 represented that the discovery associated with this case includes approximately 4, 423 pages of investigative reports and related documents in electronic form. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b. Counsel for the defendant desires additional time to consult with his respective client, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with his client, to prepare pretrial motions, and to otherwise prepare for trial.
c. Counsel for the defendant believes that failure to grant the above-requested continuance would deny the defendant the reasonable time necessary for effective preparation, taking into ...