United States District Court, E.D. California
LAW OFFICES OF CHRIS COSCA, CHRIS COSCA (SBN 144546), WILLIAM WONG, Assistant United States Attorney, Sacramento, CA, Attorney for Defendant, JEREMY LOUDEN.
STIPULATION AND ORDER TO EXCLUDE TIME AND CONTINUE STATUS CONFERENCE
JOHN A. MENDEZ, 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, the court set this matter for a status conference on February 18, 2014.
2. By this stipulation, defendant now moves to vacate this date and reset the status conference for May 6, 2014 at 9:45 a.m.
3. The parties further stipulate to exclude time between February 18, 2014 and May 6, 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. Counsel for defendant desires additional time to review and copy discovery, to conduct additional investigation, to conduct necessary legal research, and to prepare for trial.
b. Counsel for defendant believes that failure to grant this request would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
c. The government does not object to the continuance.
d. 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 original date prescribed by the Speedy Trial Act.
e. 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 February 18, 2014 to May 6, 2014, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), and 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 served by taking such action outweigh the best interest of the public and the defendants in a speedy trial.
5. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from ...