United States District Court, E.D. California
Betty J. Williams (SB# 224793) Law Office of Williams & Associates, PC Sacramento, California Attorneys for Defendant
Phillip A. Talbert, Assistant United States Attorney
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, 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 February 20, 2014.
2. By this stipulation, defendant now moves to continue the status conference until May 15, 2014, at 9:30 a.m., and to exclude time between February 20, 2014 and May 15, 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 produced over 4, 000 pages of discovery associated with this case for defendant to review.
b. The defendant submitted a proffer to the government and subsequently reviewed additional substantial documents provided by the government.
c. In July 2013, defendant submitted over 500 pages of additional supplemental documents to the government for review.
d. Counsel for both parties desire additional time to meet and discuss possible case resolution without trial.
e. Given the foregoing good-faith efforts by both sides to resolve the case short of trial, the parties agree that failure to grant the above-requested continuance would deny counsel for both sides the reasonable time necessary for effective ...