Opinion
Shari Rusk, Attorney at Law Sacramento, California Attorney for Defendant Richard O'Connell
Danny Brace, Jr. Attorney for Jermain Newman
Dina Santos Attorney for Coral Wilson
Michael Chastaine Attorney for Glenn Barrows
Chris Cosca Attorney for Frank Lobatos
Benjamin Galloway Attorney for Krislen Bridges
Kristy Kellog Attorney for Meuy Lai Saechao
STIPULATION & ORDER TO CONTINUE STATUS CONFERENCE
JOHN A. MENDEZ, District Judge.
Plaintiff, United States of America, by and through its counsel of record Olusere Olowoyeye, and defendants, Coral Wilson, Glenn Barrows, Jermaine Newman, Frank Lobatos, Krislen Bridges, Meuy Lai Saechao and Richard O'Connell by and through their undersigned counsel of record hereby stipulate as follows:
1. By previous order, this matter was set for April 7, 2015
2. By this stipulation, the defendant now moves to continue the status conference until May 12, 2015 at 9:15 a.m. and to exclude time between April 7th, 2015 and May 12, 2015 under local code T4. Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. Defense counsel needs more time to consult with defendants regarding their case.
b. Counsel for the defendants believe that failure to grant the above requested continuance would deny them reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
c. The government does not object to the continuance.
d. Based on the above stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendants in a trial within the original date prescribed by the Speedy Trial Act.
e. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. 3161, et. seq., within which trial must commence, the time period of April 7, 2015 to May 12, 2015 inclusive, is deemed excludable pursuant to 18 U.S.C. 3161(h)(7)(A), B(iv)[Local Code T4] because it results from a continuance granted by the Court at defendants request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendants in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.
ORDER
IT IS SO ORDERED.