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U.S. v. Collins, 2:15-CR-00176 TLN. (2017)

Court: District Court, E.D. California Number: infdco20170109521 Visitors: 3
Filed: Jan. 06, 2017
Latest Update: Jan. 06, 2017
Summary: STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE TROY L. NUNLEY , District Judge . STIPULATION Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Andr M. Espinosa, defendant Boone B. Khoonsrivong, by and through his counsel, Matthew C. Bockman, defendant Thongchone Vongdeng, by and through his counsel, John R. Manning, defendant Meghan Paradis, by and through her counsel, Michael B. Bigelow, defendant Joffrey Brown, by and through his coun
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STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney André M. Espinosa, defendant Boone B. Khoonsrivong, by and through his counsel, Matthew C. Bockman, defendant Thongchone Vongdeng, by and through his counsel, John R. Manning, defendant Meghan Paradis, by and through her counsel, Michael B. Bigelow, defendant Joffrey Brown, by and through his counsel, Todd Leras, and defendant Amber Collins, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, January 12, 2017 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to March 16, 2017 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.

The reason for this request is that the defense is still engaged in investigation and other defense preparation. Further, plea agreements have been conveyed to all defendants; however, defense counsel need additional time to evaluate the agreements and to discuss them with their clients. The Court is advised that Mr. Espinosa concurs with this request and that all counsel named above have authorized Ms. Radekin to sign this stipulation on their behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until March 16, 2017 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED.

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of January 12, 2017 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on March 16, 2017 at 9:30 a.m. The Court finds excludable time in this matter through March 16, 2017 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.

Source:  Leagle

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