Filed: Feb. 18, 2015
Latest Update: Feb. 18, 2015
Summary: STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE MORRISON C. ENGLAND, Jr., District Judge. The United States of America, by and through Assistant U.S. Attorney Jared C. Dolan; defendant Mohammad Riaz Khan, by and through counsel Scott L. Tedmon; defendant Mohammad Shahbaz Khan, by and through counsel Olaf W. Hedberg; defendant Harjit Kaur Johal, by and through counsel Gilbert A. Roque; and defendant Hamira Chechi, by and through counsel Michael J. Aye; hereby stipulate and agree as f
Summary: STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE MORRISON C. ENGLAND, Jr., District Judge. The United States of America, by and through Assistant U.S. Attorney Jared C. Dolan; defendant Mohammad Riaz Khan, by and through counsel Scott L. Tedmon; defendant Mohammad Shahbaz Khan, by and through counsel Olaf W. Hedberg; defendant Harjit Kaur Johal, by and through counsel Gilbert A. Roque; and defendant Hamira Chechi, by and through counsel Michael J. Aye; hereby stipulate and agree as fo..
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STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., District Judge.
The United States of America, by and through Assistant U.S. Attorney Jared C. Dolan; defendant Mohammad Riaz Khan, by and through counsel Scott L. Tedmon; defendant Mohammad Shahbaz Khan, by and through counsel Olaf W. Hedberg; defendant Harjit Kaur Johal, by and through counsel Gilbert A. Roque; and defendant Hamira Chechi, by and through counsel Michael J. Aye; hereby stipulate and agree as follows:
1. The status conference is currently set for February 19, 2015 at 9:00 a.m.
2. By this stipulation, the parties now move to continue the status conference to Thursday, March 26, 2015 at 9:00 a.m., and to exclude time from February 19, 2015 through March 26, 2015 under Local Code T4.
3. The basis upon which the parties agree to this proposed continuance of the status conference is as follows:
a. First, the government has produced in excess of 5,000 pages of discovery which to date includes witness statements, tape recordings, and investigative materials. Given the volume of documents, defense counsel needs some additional time to continue to analyze the discovery, conduct defense investigation, and review the matter with each counsel's respective client.
b. Counsel for each defendant believes that failure to grant the above-requested continuance would deny his client 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 status conference as requested outweigh the best 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, 16 U.S.C. § 3161, et seq., within which trial must commence, the time period from February 19, 2015 to March 26, 2015, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(a), B(iv); [Local Code T4] because it results from a continuance by the Court at the 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 defendant in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that the additional time periods are excludable from the period within which a trial must commence.
5. Finally, Scott L. Tedmon has been authorized by each party to sign this stipulation on their behalf.
Based on the foregoing, the undersigned parties agree and stipulate the February 19, 2015 status conference be continued to March 26, 2015 at 9:00 a.m.
DATED: February 12, 2015 BENJAMIN B. WAGNER
United States Attorney
/s/ Jared C. Dolan
JARED C. DOLAN
Assistant United States Attorney
ORDER
IT IS SO ORDERED.
