Opinion
No. CR-S-11-00084 GEB
04-03-2013
UNITED STATES OF AMERICA, Plaintiff, v. GREGORY CHMIELEWSKI, Defendants.
JOSEPH SCHLESINGER Acting Federal Defender DOUGLAS BEEVERS Assistant Federal Defender Attorney for Defendant GREGORY CHMIELEWSKI BENJAMIN B. WAGNER United States Attorney LEE BICKLEY Assistant United States Attorney Attorney for Plaintiff
JOSEPH SCHLESINGER, Bar #87962
Acting Federal Defender
DOUGLAS BEEVERS, Bar #288639
Assistant Federal Defender
Designated Counsel for Service
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
GREGORY CHMIELEWSKI
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE STATUS CONFERENCE
Date: June 14, 2013
Judge: Hon. Garland E. Burrell, Jr.
The parties request that the status conference in this case be continued from April 5, 2013, to June 14, 2013 at 9:00 a.m. They stipulate that the time between April 5, 2013 and June 14, 2013 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C §3161(h)(7)(A) and (B)(iv)and Local Code T-4. Defense counsel needs additional time to investigate the facts of the case and to negotiate a resolution to this matter. Specifically, defense counsel needs additional time to review and examine the several hundred thousand pages of discovery that the Government has disclosed. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(7)(A) and (B)(iv)and Local Code T-4.
Respectfully submitted,
JOSEPH SCHLESINGER
Acting Federal Defender
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DOUGLAS BEEVERS
Assistant Federal Defender
Attorney for Defendant
GREGORY CHMIELEWSKI
BENJAMIN B. WAGNER
United States Attorney
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LEE BICKLEY
Assistant United States Attorney
Attorney for Plaintiff
ORDER
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for April 5, 2013, be continued to June 14, 2013, at 9:00 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time from the date of this Order, to and including, the June 14, 2013, status conference shall be excluded from computation of time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C §3161(h)(7)(A) and (B)(iv) and Local Code T-4.
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GARLAND E. BURRELL, JR.
Senior United States District Judge