Opinion
ERIN J. RADEKIN Attorney at Law Sacramento, California Attorney for Defendant TOU HER
RONALD PETERS Attorney for Defendant STEVEN KHAMKEUANEKEO
GREG FOSTER Attorney for Defendant KAY LEE
MATTHEW SCOBLE Attorney for Defendant CHEE YANG
ERIN J. RADEKIN Attorney for Defendant TOU HER
DANNY BRACE Attorney for Defendant FRANK HER
DAVID FISCHER Attorney for Defendant LEE YANG
DUSTIN JOHNSON Attorney for Defendant AMY HER
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Matthew M. Yelovich, defendant, Steven Khamkeuanekeo, by and through his counsel, Ronald Peters, defendant, Kay Lee, by and through her counsel, Greg Foster, defendant, Chee Yang, by and through his counsel, Matthew Scoble, defendant, Tou Her, by and through his counsel, Erin J. Radekin, defendant, Frank Her, by and through his counsel, Danny Brace, defendant, Lee Yang, by and through his counsel, David Fischer, and defendant, Amy Her, by and through her counsel, Dustin Johnson, agree and stipulate to vacate the date set for status conference, September 3, 2015 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to January 7, 2016 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.
The reason for this request is that additional time is needed by the defense to complete review of discovery, which is presently numbered through item/page number 6498, for investigation, and for other defense preparation. The Court is advised that Mr. Yelovich and all defense counsel referenced above concur with this request and have authorized Ms. Radekin to sign this stipulation on their behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until January 7, 2016 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of September 3, 2015 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on January 7, 2016 at 9:30 a.m. The Court finds excludable time in this matter through January 7, 2016 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.