Filed: Apr. 20, 2018
Latest Update: Apr. 20, 2018
Summary: STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE WILLIAM B. SHUBB , District Judge . It is hereby stipulated between the parties, Brian Fogerty, Assistant United States Attorney, Ruzanna Poghosyan, attorney for defendant OGANES EMIRZYAN, and Michael D. Long, attorney for defendant MKRTYCH SARGSYAN, that the status conference set for April 23, 2018, at 9:00 a.m. should be vacated and re-set for May 21, 2016, at 9:00 a.m. The parties further agree that this court should make a fin
Summary: STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE WILLIAM B. SHUBB , District Judge . It is hereby stipulated between the parties, Brian Fogerty, Assistant United States Attorney, Ruzanna Poghosyan, attorney for defendant OGANES EMIRZYAN, and Michael D. Long, attorney for defendant MKRTYCH SARGSYAN, that the status conference set for April 23, 2018, at 9:00 a.m. should be vacated and re-set for May 21, 2016, at 9:00 a.m. The parties further agree that this court should make a find..
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STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE
WILLIAM B. SHUBB, District Judge.
It is hereby stipulated between the parties, Brian Fogerty, Assistant United States Attorney, Ruzanna Poghosyan, attorney for defendant OGANES EMIRZYAN, and Michael D. Long, attorney for defendant MKRTYCH SARGSYAN, that the status conference set for April 23, 2018, at 9:00 a.m. should be vacated and re-set for May 21, 2016, at 9:00 a.m.
The parties further agree that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown. Both defense attorneys are fairly new to the case. Each defense attorney is still reading the over 600 pages of reports and 89 discs of information, most of which are audio and video recordings. Each defense lawyer must continue to investigate the case. All parties are available to appear in this case on May 21, 2018.
Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Each party would like time to be excluded, as provided by Local Code T4 and in the Speedy Trial Act, 18 U.S.C. § 3161, et seq., from today's date through May 21, 2018, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv). Time has already been excluded until the date of the presently set status date of April 23, 2018.
All parties request the date of May 21, 2017, for the status hearing. The request for extending the date for the status conference is at the specific request of both defendants and with the knowing, intelligent and voluntary waiver of each defendant's speedy trial rights under the law. The government agrees that a continuance is necessary. Good cause is hereby shown.
GOOD CAUSE APPEARING AND HAVING BEEN SHOWN, IT IS SO ORDERED.
The date for the status hearing in this matter is hereby re-set for May 21, 2018, at 9:00 a.m., before District Court Judge William B. Shubb. Time has previously been excluded until April 23, 2018. Time is excluded, as provided by Local Code T4 and in the Speedy Trial Act, 18 U.S.C. § 3161, et seq., from today's date through May 21, 2018.
