STIPULATION AND [PROPOSED] ORDER MOVING DEADLINES FOR PRETRIAL FILINGS

EDWARD M. CHEN, District Judge.

The parties hereby request that the deadline for pre-trial filings as to Jilian Zhang be moved from Tuesday, March 10, 2015 to Friday, March 13, 2015. This proposed stipulation would not affect the trial date as to Mr. Zhang, nor would it change the date for the Pretrial Conference.1

The First Amended Pretrial Order sets forth the applicable deadlines for trial in this case, which is set for April 20, 2015. (Docket No. 81). Motions in limine and other pre-trial motions are due to be filed on March 10, 2015. Responses to motions are due on March 17, 2015. Other filings, such as exhibit lists and witness lists, are also due three weeks before the Pretrial Conference.

This proposed extension would move all of these deadlines by three days. The deadline for pre-trial filings would move to Friday, March 13th. The deadline for responses would move to Friday, March 20th. The deadlines for other matters, including exhibit lists and witness lists, would also be moved by three days. The Pretrial Conference would remain on March 31, 2015, and the date for the trial would remain on April 20, 2015.

As a basis for this request, the government notes that counsel for Mr. Zhang has moved for a competency exam and hearing. (Docket No. 105.) In this filing, counsel for Mr. Zhang also requested that the trial date and the associated deadlines be vacated. (Id.) The Court has set a hearing on this motion for Wednesday, March 11th at 2:30 p.m.

The deadline for pre-trial filings under the Court's prior order remains on March 10th, one day before the hearing on the competency motion. This stipulation acknowledges that the hearing on this motion may affect the status of trial, but it does not vacate any trial dates or associated dates until after the Court has had an opportunity to review the competency motion.

SO STIPULATED:

[PROPOSED] ORDER

Based upon the representation of counsel and for good cause shown, the Court hereby provides additional time as to the pre-trial filings applicable to defendant Jilian Zhang. This order affects the deadlines set forth in the Court's First Amended Pretrial Order. (Docket No. 81.)

Motions in limine and other pre-trial motions shall be filed by March 13, 2015. Responses to these motions will be due on March 20, 2015.

Similarly, deadlines for the pretrial statement, trial brief, joint exhibit list, witness list, proposed jury instructions, proposed verdict form, proposed questions for jury voir dire — as set forth in Paragraph 4(b) of the Court's First Amended Pretrial Order — shall also be moved by three days. Deadlines for responses to these materials — as set forth in Paragraph 4(c) — are also moved by three days.

IT IS SO ORDERED.