Opinion
MICHAEL D. LONG, Sacramento, CA, Attorney for DAVID BENNETT.
CLYDE BLACKMON, Attorney for Joseph Latu.
KYLE KNAPP, Attorney for Algernon Tamasoa.
JEFF STANIELS, Attorney for John Ortiz.
CHRIS COSCA, Attorney for Keith White.
OLAF HEDBERG, Attorney for Charles Tucker.
SHARI RUSK, Attorney for Ionel Pascan.
STEVE PLESSER, Attorney for Daniel Bennett.
STIPULATION AND ORDER TO STATUS CONFERENCE
JOHN A. MENDEZ, District Judge.
It is hereby stipulated between the parties, Christiian Highsmith, Assistant United States Attorney, Michael D. Long, attorney for defendant DAVID BENNETT, Clyde Blackmon, attorney for defendant JOSEPH LATU, Kyle Knapp, attorney for defendant ALGERNON TAMASOA, Jeff Staniels, attorney for defendant JOHN ORTIZ, Chris Cosca, attorney for defendant KEITH WHITE, Olaf Hedberg, attorney for defendant CHARLES TUCKER, Shari Rusk, attorney for defendant Ionel Pascan, and Steve Plesser, attorney for defendant DANIEL BENNETT that the status conference set for November 10, 2015, at 9:15 a.m. should be vacated and re-set for January 12, 2016, at 9:15 a.m.
The parties further agree, pursuant to Fed.R.Crim.Pro.5.1(c) and (d), that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown. The Government is about to provide the defense with 41 DVDs containing many hours of audios and videos of recorded conversations, recorded meetings, photographs and documents. Defense counsel will need to review the discovery, meet with clients and develop defenses. All defense counsel will need to meet and confer with each other about defenses.
Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Each party would like time to be excluded as provided by Local Code T4 from today's date through January 12, 2016, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv).
All parties request the date of January 12, 2016, for the status hearing. The request for extending the date for the status conference is at the specific request of the defendants and with the knowing, intelligent and voluntary waiver of their speedy trial rights under the law. Good cause is hereby shown.
ORDER
GOOD CAUSE APPEARING AND HAVING BEEN SHOWN, IT IS SO ORDERED
The date for the preliminary hearing in this matter is hereby re-set for January 12, 2016, at 9:15 a.m., before District Court Judge John A. Mendez. The court finds that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Time is excluded as provided by Local Code T4 from today's date through January 12, 2016, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv).