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U.S. v. KLIPP, 2:14-cr-00107-TLN-1. (2015)

Court: District Court, E.D. California Number: infdco20150415906 Visitors: 8
Filed: Apr. 13, 2015
Latest Update: Apr. 13, 2015
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFRENCE AND EXCLUDE TROY L. NUNLEY , District Judge . Joshua L. Klipp, by and through his counsel, Jan David Karowsky, and the United States Government, by and through its counsel, Andre M. Espinosa, Assistant United States Attorney, hereby stipulate and agree to vacate the previously scheduled Status Conference Date of April 16, 2015 at 9:30 a.m. and re-set the status conference date to June 18, 2015 at 9:30 a.m. Counsel for defendant was just
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STIPULATION AND ORDER TO CONTINUE STATUS CONFRENCE AND EXCLUDE

Joshua L. Klipp, by and through his counsel, Jan David Karowsky, and the United States Government, by and through its counsel, Andre M. Espinosa, Assistant United States Attorney, hereby stipulate and agree to vacate the previously scheduled Status Conference Date of April 16, 2015 at 9:30 a.m. and re-set the status conference date to June 18, 2015 at 9:30 a.m.

Counsel for defendant was just recently substituted in for prior counsel. Counsel for Defendant is still reviewing the discovery, determining the extent of the forensic work which has been undertaken by prior counsel, and just initiating needed investigation. Without the additional time, defense counsel cannot adequately advise his client concerning the options available to the Defendant in this matter and certainly cannot effectively prepare for trial, if such is necessary.

It is further stipulated and agreed between the parties that the period beginning April 16, 2015 to June 18, 2015, should be excluded in computing the time within which the trial of the above criminal prosecution must commence for purposes of the Speedy Trial Act for defense preparation.

All parties stipulate and agree that this is an appropriate exclusion of time within the meaning of Title 18, United States Code, Section 3161 (h) (8) (iv) (Local Code T4).

IT IS SO STIPULATED.

DATED: April 13, 2015 BENJAMIN B. WAGNER United States Attorney André Espinosa by Jan Karowsky With Mr. Espinosa's permission by André Espinosa Assistant U.S. Attorney

ORDER

The parties' stipulation is approved and so ordered. The time beginning April 16, 2015 to June 18, 2015, is excluded from the calculation of time under the Speedy Trial Act. For the reasons contained in the parties' stipulation, this exclusion is appropriate to ensure effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4. The interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A)

Source:  Leagle

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