The Law Office of Olaf W. Hedberg Olaf W. Hedberg, State Bar #151082 Sacramento, California, Olaf W. Hedberg, Attorney for Pavel Yakimenko.
David Fischer, Attorney for Nikolay Yakimenko
Stanley Kubochi, Attorney for Yuriy Kaltachi
Timothy Zindel, Attorney for Svetlana Kramarenko
STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
Plaintiff United States of America, by and through its counsel of record, and the defendants, by and through each counsel of record, hereby stipulate as follows:
1. By this stipulation, the defendants now move to continue the status conference until April 10, 2014, and to exclude time between January 16, 2014, and April 10, 2014, under Local Code T4. Plaintiff does not oppose this request.
2. The parties agree and stipulate, and request that the Court find the following:
a. Since the time of the last status conference the government has provided additional discovery associated with this case that consists of more than 7, 000 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 defendants desire additional time to consult with their respective clients, 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 their clients, to prepare pretrial motions, and to otherwise prepare for trial.
c. Counsel for the defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
d. The government does not object to the continuance.
e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendants in a trial within the original date prescribed by the Speedy Trial Act.
f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of January 16, 2014, to April 10, 2014, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice ...