Filed: Jun. 25, 2019
Latest Update: Jun. 25, 2019
Summary: Stipulation to Reset Deadline (First Request) CAM FERENBACH , Magistrate Judge . It is hereby stipulated and agreed, by and between Nicholas A. Trutanich, United States Attorney, and Robert Knief, Assistant United States Attorney, counsel for the United States of America, and Nicholas Wooldridge, counsel for defendant Chang Zheng, that the deadline for the government to respond to defendant's Motion to Suppress Evidence (ECF #200 for August 2, 2019, or a date thereabouts convenient for the
Summary: Stipulation to Reset Deadline (First Request) CAM FERENBACH , Magistrate Judge . It is hereby stipulated and agreed, by and between Nicholas A. Trutanich, United States Attorney, and Robert Knief, Assistant United States Attorney, counsel for the United States of America, and Nicholas Wooldridge, counsel for defendant Chang Zheng, that the deadline for the government to respond to defendant's Motion to Suppress Evidence (ECF #200 for August 2, 2019, or a date thereabouts convenient for the ..
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Stipulation to Reset Deadline
(First Request)
CAM FERENBACH, Magistrate Judge.
It is hereby stipulated and agreed, by and between Nicholas A. Trutanich, United States Attorney, and Robert Knief, Assistant United States Attorney, counsel for the United States of America, and Nicholas Wooldridge, counsel for defendant Chang Zheng, that the deadline for the government to respond to defendant's Motion to Suppress Evidence (ECF #200 for August 2, 2019, or a date thereabouts convenient for the Court.
This stipulation is entered into for the following reasons
1. At the time defendant filed the motion, counsel for the government was on a absent from the office. Counsel for the government needs the additional time to properly prepare a response.
2. The parties are engaged in negotiations that will likely resolve the without the need to resolve the suppression issue.
3. Defendant is not in custody and does not object to the continuance.
4. For the reasons stated above, the ends of justice would best be served by a continuance of the government deadline.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
6. This request does not extend the trial date and no waiver or extension of speedy trial is necessary.
7. This is the first request for a continuance filed herein.
DATED this 25th day of June, 2019.
Respectfully submitted,
Nicholas A. Trutanich
United States Attorney
/s/ Nicholas Wooldridge /s/ Robert Knief
Nicholas Woolridge Robert Knief
Counsel for Defendant Assistant United States Attorney
FINDINGS OF FACT
Based upon the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:
1. At the time defendant filed the motion, counsel for the government was on a absent from the office. Counsel for the government needs the additional time to properly prepare a response.
2. The parties are engaged in negotiations that will likely resolve the without the need to resolve the suppression issue.
3. Defendant is not in custody and does not object to the continuance.
4. For the reasons stated above, the ends of justice would best be served by a continuance of the government deadline.
5. Additionally, denial of this request for continuance could result in a miscarriage of justice.
CONCLUSIONS OF LAW
The ends of justice served by granting said continuance outweigh the best interest of the public and the Defendant in a speedy trial, since the failure to grant said continuance would be likely to result in a miscarriage of justice, would deny the parties herein sufficient time and the opportunity within which to be able to effectively prepare a response, taking into account the exercise of due diligence.
ORDER
IT IS THEREFORE ORDERED that the government response to defendant's Motion to Suppress (ECF #200), is due by the close of business on the 2nd day of August, 2019.
