Filed: Sep. 24, 2014
Latest Update: Sep. 24, 2014
Summary: STIPULATION AND [] ORDER TO CONTINUE STATUS CONFERENCE AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT D. LOWELL JENSEN, District Judge. IT IS HEREBY STIPULATED AND AGREED between the Government, through Assistant United States Attorney Thomas Moore, and Defendant Sanjeev Bais, through his attorney Daniel Olmos, that the status conference presently set for September 25, 2014, be continued to October 30, 2014, at 9:00 a.m. The reason for the request for continuance is that defense counsel is cur
Summary: STIPULATION AND [] ORDER TO CONTINUE STATUS CONFERENCE AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT D. LOWELL JENSEN, District Judge. IT IS HEREBY STIPULATED AND AGREED between the Government, through Assistant United States Attorney Thomas Moore, and Defendant Sanjeev Bais, through his attorney Daniel Olmos, that the status conference presently set for September 25, 2014, be continued to October 30, 2014, at 9:00 a.m. The reason for the request for continuance is that defense counsel is curr..
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STIPULATION AND [] ORDER TO CONTINUE STATUS CONFERENCE AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT
D. LOWELL JENSEN, District Judge.
IT IS HEREBY STIPULATED AND AGREED between the Government, through Assistant United States Attorney Thomas Moore, and Defendant Sanjeev Bais, through his attorney Daniel Olmos, that the status conference presently set for September 25, 2014, be continued to October 30, 2014, at 9:00 a.m. The reason for the request for continuance is that defense counsel is currently in trial in San Mateo County Superior Court, and has been for several weeks. The trial is expected to continue through the week of September 29, 2014. In addition, government counsel is unavailable between October 8 and 17, 2014. Defense counsel has provided discovery to the government, but the parties have been unable to meet and confer regarding the material primarily because of counsel's jury trial, and likely will not be able to do so until after October 17. The parties do anticipate that the October 30 date can serve as a plea or set date provided that they can meet prior to that date.
The parties agree that the time between September 25 and October 30, 2014, should be excluded from calculations under the Speedy Trial Act, which excludes delay when the interests of justice in allowing for the effective preparation of the government and the defense, as well as continuity of counsel, outweigh the best interest of the public and the defendant in a speedy trial, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7).
IT IS SO STIPULATED:
Dated: September 22, 2014.
/s/
THOMAS MOORE
Assistant United States Attorney
[]ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT
GOOD CAUSE HAVING BEEN SHOWN, it is hereby ordered that the status conference in this matter now scheduled for September 25, 2014, be continued to October 30, 2014, at 9:00 a.m. Based upon the representation of counsel and for good cause shown, the Court also finds that the time between September 25 and October 30, 2014, shall be excluded from calculations under the Speedy Trial Act. The interests of justice in allowing for the effective preparation of the defense and continuity of counsel outweigh the best interest of the public and the defendant in a speedy trial, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7).
