Filed: Aug. 06, 2018
Latest Update: Aug. 06, 2018
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER TO CONTINUE CASE TO 10/11/2018 AT 10:00 A.M. MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, Cameron Desmond, and Defendant Celeste Pang, represented by Attorney Dina Santos, hereby stipulate as follows: 1. By previous order, this matter was set for status on August 20, 2018. 2. By this stipulation, defendants now move to continue t
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER TO CONTINUE CASE TO 10/11/2018 AT 10:00 A.M. MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, Cameron Desmond, and Defendant Celeste Pang, represented by Attorney Dina Santos, hereby stipulate as follows: 1. By previous order, this matter was set for status on August 20, 2018. 2. By this stipulation, defendants now move to continue th..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER TO CONTINUE CASE TO 10/11/2018 AT 10:00 A.M.
MORRISON C. ENGLAND, JR., District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, Cameron Desmond, and Defendant Celeste Pang, represented by Attorney Dina Santos, hereby stipulate as follows:
1. By previous order, this matter was set for status on August 20, 2018.
2. By this stipulation, defendants now move to continue the status conference until October 11, 2018, and to exclude time between August 20, 2018, and October 11, 2018, under Local Code T4. Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a) Counsel for defendant desire additional time to continue to review discovery, conduct investigation, and to otherwise prepare for trial. Discovery to this point consists of approximately 98 separate electronic files that contain 18 separate video/audio files of recordings, numerous excel spreadsheets, and other written discovery. Counsel for defendant believes that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The government does not object to the continuance. In addition to the time required to continue investigation and prepare for trial.
b) Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.
c) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of August 20, 2018, to October 11, 2018, 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 granted by the Court at 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 additional time periods are excludable from the period within which a trial must commence.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.
