Michael E. Hansen, Attorney at Law, SBN 191737, Sacramento, CA, Attorney for Defendant, VALERI KALYUZHNYY.
BENJAMIN B. WAGNER, United States Attorney.
LEE BICKLEY, Assistant U.S. Attorney, Attorney for Plaintiff.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE, AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT
MORRISON C. ENGLAND, Jr., Chief District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on January 23, 2014.
2. By this stipulation, defendant now moves to continue the status conference until June 19, 2014, and to exclude time between January 23, 2014, and June 19, 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 3, 850 pages. Additionally, over 7, 000 pages of discovery has been provided by the Government in two related cases (U.S. v. Mysin, et al. (Case No. 2:11-CR-00427-LKK) and U.S. v. Beknazarov, et al. (Case No. 2:12-CR-00051-MCE)), and Mr. Hansen needs time to review that discovery, as well.
b. Counsel for defendant desires additional time to review discovery with the defendant, to examine possible defenses and to continue investigating the facts of the case.
c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him 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 defendant in a trial within the ...