Opinion
NO. 1:11-cr-0352 LJO-SKO
01-31-2013
UNITED STATES OF AMERICA, Plaintiff, v. MARK BAGDASARIAN, RYAN BAGDASARIAN, Defendants.
JOSEPH SCHLESINGER, Bar #87692 Acting Federal Defender JEREMY S. KROGER, Bar #258956 CHARLES J. LEE, Bar #221057 Assistant Federal Defender Designated Counsel for Service Attorneys for Defendant RYAN BAGDASARIAN ELANA S. LANDAU Assistant United States Attorney Attorney for Plaintiff ANTHONY P. CAPOZZI Attorney for Defendant Mark Bagdasarian
JOSEPH SCHLESINGER, Bar #87692
Acting Federal Defender
JEREMY S. KROGER, Bar #258956
CHARLES J. LEE, Bar #221057
Assistant Federal Defender
Designated Counsel for Service
Attorneys for Defendant
RYAN BAGDASARIAN
AMENDED STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE HEARING
DATE: April 15, 2013
JUDGE: Hon. Sheila K. Oberto
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Elana S. Landau, Counsel for Plaintiff, Anthony P. Capozzi, Counsel for Defendant Mark Bagdasarian, and Charles J. Lee, Counsel for Defendant Ryan Bagdasarian, that the status conference in the above-captioned matter now set for February 4, 2013, may be continued to April 15, 2013 at 1:00 p.m. before Magistrate Sheila K. Oberto.
This continuance is at the request of all parties. Both defense counsel have engaged in substantive plea negotiations on the case and have met several times with the government. However, the parties have been unable to finalize the potential plea agreements as counsel for the government is currently in day 13 of jury trial before Judge Ishii. The parties believe with the additional time a pretrial resolution will be reached in this case.
The requested continuance is with the intention of conserving time and resources for both parties and the court. The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation, defense investigation, and plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
By: _______________
ELANA S. LANDAU
Assistant United States Attorney
Attorney for Plaintiff
_______________
ANTHONY P. CAPOZZI
Attorney for Defendant
Mark Bagdasarian
JOSEPH SCHLESINGER
Acting Federal Defender
_______________
CHARLES J. LEE
Assistant Federal Defender
Attorneys for Defendant
Ryan Bagdasarian
ORDER
IT IS SO ORDERED. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
The parties are to be prepared to select a mutually agreeable trial date at the April 15, 2013, hearing if they are unable to achieve a pretrial resolution prior to that date. IT IS SO ORDERED.
Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE