Opinion
No. 2:11-CR-0274 JAM
03-22-2013
UNITED STATES OF AMERICA, Plaintiff, v. CEM KIYAK, Defendant.
BENJAMIN B. WAGNER United States Attorney T. Zindel for T. Pickles TODD PICKLES Assistant U.S. Attorney JOSEPH SCHLESINGER Acting Federal Defender TIMOTHY ZINDEL Assistant Federal Defender Attorney for CEM KIYAK
JOSEPH SCHLESINGER, Bar #87692
Acting Federal Defender
TIMOTHY ZINDEL, Bar #158377
Assistant Federal Defender
801 I Street, 3rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
CEM KIYAK
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE
AND EXCLUDE TIME
Date: March 26, 2013
Judge: Hon. John A. Mendez
IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendant, Cem Kiyak, that the status conference scheduled for March 26, 2013, may be continued to May 14, 2013, at 9:45 a.m.
The defense continues its review of the evidence. Counsel has also retained an immigration expert for research and advice about the possible immigration consequences of various resolutions - a matter of considerable importance to the defense because the Kiyaks have a child with special needs. The expert is expected to continue her work through April. The parties agree that additional time is needed before the case may be resolved or further scheduled. They also agree that the interests of justice to be served by a continuance therefore outweigh the best interests of the parties in a speedy trial, so that time under the Speedy Trial Act should be excluded from the date of this order through the status conference on May 14, 2013, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).
Respectfully submitted,
BENJAMIN B. WAGNER
United States Attorney
T. Zindel for T. Pickles
TODD PICKLES
Assistant U.S. Attorney
JOSEPH SCHLESINGER
Acting Federal Defender
_________________
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for CEM KIYAK
ORDER
The status conference is continued to May 14, 2013, at 9:45 a.m. Time under the Speedy Trial Act is excluded through that date for the reasons stated above and by agreement of the parties, the Court finding that the ends of justice to be served by a continuance outweigh the best interests of the defendant and the public in a speedy trial for the reasons stated above.
IT IS SO ORDERED.
_________________
HON. JOHN A. MENDEZ
United States District Court Judge