Filed: Mar. 26, 2015
Latest Update: Mar. 26, 2015
Summary: STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE MORRISON C. ENGLAND, Jr. , Chief District Judge . The United States of America, by and through Assistant U.S. Attorney Heiko P. Coppola; defendant Aleksandr Lastovskiy, by and through counsel Kenny N. Giffard; defendant Tatyana Shvets, by and though counsel Joseph A. Welch; defendant Aleksandr Mikhaylov, by and through counsel Scott L. Tedmon; and defendant Hovik Mkrtchian, by and through counsel Richard E. Nahigian, hereby stipulat
Summary: STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE MORRISON C. ENGLAND, Jr. , Chief District Judge . The United States of America, by and through Assistant U.S. Attorney Heiko P. Coppola; defendant Aleksandr Lastovskiy, by and through counsel Kenny N. Giffard; defendant Tatyana Shvets, by and though counsel Joseph A. Welch; defendant Aleksandr Mikhaylov, by and through counsel Scott L. Tedmon; and defendant Hovik Mkrtchian, by and through counsel Richard E. Nahigian, hereby stipulate..
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STIPULATION AND ORDER RE: CONTINUANCE OF STATUS CONFERENCE
MORRISON C. ENGLAND, Jr., Chief District Judge.
The United States of America, by and through Assistant U.S. Attorney Heiko P. Coppola; defendant Aleksandr Lastovskiy, by and through counsel Kenny N. Giffard; defendant Tatyana Shvets, by and though counsel Joseph A. Welch; defendant Aleksandr Mikhaylov, by and through counsel Scott L. Tedmon; and defendant Hovik Mkrtchian, by and through counsel Richard E. Nahigian, hereby stipulate and agree as follows:
1. The status conference is currently set for March 26, 2015 at 9:00 a.m.
2. By this stipulation, the above-named defendants now move to continue the status conference to Thursday, June 4, 2015 at 9:00 a.m., and to exclude time from March 26, 2015 through June 4, 2015 under Local Code T4. Plaintiff does not oppose this request.
3. The basis upon which the parties agree to this proposed continuance of the status conference is as follows:
a. The government has produced voluminous discovery containing witness statements, banking records, and investigative materials. The government advises it will soon be producing additional discovery to defense counsel. As such, defense counsel needs additional time to review and analyze the additional discovery produced by the government, conduct independent defense investigation, and consult with their respective clients.
b. Counsel for each defendant believes that failure to grant the above-requested continuance would deny their respective client the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
c. Plaintiff 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 defendants 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 March 26, 2015 to June 4, 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 defendants 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 defendants 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 all counsel to sign this stipulation on their behalf.
Based on the foregoing, the undersigned parties agree and stipulate the March 26, 2015 status conference be continued to June 4, 2015 at 9:00 a.m.
IT IS SO STIPULATED.
DATED: March 23, 2015 BENJAMIN B. WAGNER
United States Attorney
/s/ Heiko P. Coppola
HEIKO P. COPPOLA
Assistant United States Attorney
ORDER
IT IS SO ORDERED.
