United States District Court, E.D. California
HEATHER E. WILLIAMS, Federal Defender, MATTHEW C. BOCKMON, Assistant Federal Defender Sacramento, CA, Attorneys for Defendant RUSSELL EUGENE GILMORE.
BENJAMIN B. WAGNER, United States Attorney, SAMUEL WONG, Assistant United States Attorney.
PATRICK K. HANLY, Counsel for Defendant, John H. Mahan MATTHEW C. BOCKMON, Counsel for Defendant, Russell E. Gilmore, MICHAEL BIGELOW Counsel for Defendant Richard D. Hemsl.
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE TO APRIL 4, 2014; EXCLUDE TIME
GARLAND E. BURRELL, Jr., District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their respective counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on February 28, 2014.
2. By this stipulation, defendants now move to continue the status conference until April 4, 2014 at 9:00 a.m., before the Honorable Garland E. Burrell Jr. and to exclude time between February 24, 2014 and April 4, 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, GILMORE, is in trial before Judge Shubb in case U.S. v. Longley, et al., (11-cr-511 WBS).
b. The government has produced initial discovery associated with this case.
c. Counsel for defendants request additional time to review discovery, to conduct investigation and research related to the charges, to discuss potential resolutions with their clients, and to otherwise prepare for trial.
d. Counsel for 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.
e. The government does not object to the continuance.
f. 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 ...