Filed: Mar. 14, 2018
Latest Update: Mar. 14, 2018
Summary: STIPULATION TO CONTINUE AND EXCLUDE TIME AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . STIPULATION The above-captioned matters are set for a status conference on Thursday, March 15, 2018. For the following reasons, the parties now stipulate and respectfully request that the status conference be continued to Wednesday, April 4, 2018, at 2:30 pm, or as soon thereafter as is convenient for the Court. Defense counsel recently produced to the government information relating to
Summary: STIPULATION TO CONTINUE AND EXCLUDE TIME AND [PROPOSED] ORDER EDWARD M. CHEN , District Judge . STIPULATION The above-captioned matters are set for a status conference on Thursday, March 15, 2018. For the following reasons, the parties now stipulate and respectfully request that the status conference be continued to Wednesday, April 4, 2018, at 2:30 pm, or as soon thereafter as is convenient for the Court. Defense counsel recently produced to the government information relating to t..
More
STIPULATION TO CONTINUE AND EXCLUDE TIME AND [PROPOSED] ORDER
EDWARD M. CHEN, District Judge.
STIPULATION
The above-captioned matters are set for a status conference on Thursday, March 15, 2018. For the following reasons, the parties now stipulate and respectfully request that the status conference be continued to Wednesday, April 4, 2018, at 2:30 pm, or as soon thereafter as is convenient for the Court.
Defense counsel recently produced to the government information relating to the defendant's medical condition, and the parties are now in discussions regarding what effect, if any, this information should have on the appropriate disposition of the case. The parties are working diligently toward a resolution of the case and anticipate that they will have a resolution to present to the Court by April 4, 2018. Accordingly, the parties respectfully request that the Court grant the requested continuance.
The parties further stipulate that the time between March 14, 2018, and April 4, 2018, should be excluded under the Speedy Trial Act pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (h)(7)(B). Particularly in light of defendant's health issues, discussed herein and on the record at prior hearings, excluding these periods of time will allow counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. See 18 U.S.C. § 3161(h)(7)(B)(iv).
IT IS SO STIPULATED.
[PROPOSED] ORDER
It is hereby ORDERED that the status conference in the above-captioned matters be continued from March 14, 2018, to April 4, 2018, at 2:30 pm.
The Court further finds that the exclusion of the period from March 14, 2018, through April 4, 2018, from the time limits applicable under 18 U.S.C. § 3161, is warranted; that the ends of justice served by the continuance outweigh the interests of the public and the defendant in the prompt disposition of this criminal case; and that the failure to grant the requested exclusion of time would unreasonably deny defense counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and would result in a miscarriage of justice. See 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).
IT IS SO ORDERED.
