Opinion
BENJAMIN B. WAGNER, United States Attorney, TODD A. PICKLES, Assistant United States Attorney, Sacramento, CA, Attorneys for Plaintiff United States of America
HAYES GABLE, ESQ. Counsel for Defendant, Dustin Wilson.
STIPULATION AND ORDER TO CONTINUE STATUS HEARING STIPULATION
TROY L. NUNLEY, District Judge.
The United States of America, by and through the undersigned Assistant United States Attorney, and defendant Dustin Wilson by and through his undersigned counsel of record, hereby agree and stipulate to the following:
1. By previous order, this matter was set for status on February 26, 2015.
2. By this stipulation, defendants now move to continue the status hearing until March 12, 2015 at 9:30 a.m. Time has already been excluded through the trial date of August 24, 2015, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) Current counsel for Mr. Wilson was appointed on January 8, 2015.
b) The government has represented that the discovery associated with this case includes 1400 pages of discovery consisting of investigative reports and bank and financial records. All of this discovery has been produced directly to Mr. Wilson's new counsel.
c) Counsel for Mr. Wilson has been informed of a criminal investigation relating to alleged trafficking narcotics to the District of Hawaii by Mr. Wilson.
d) Counsel for Mr. Wilson desires additional time to review discovery, to consult with his client and conduct research with respect to the possibility of additional charges being brought, and to discuss potential resolution with his client.
e) Counsel for defendant believes that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
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.
IT IS SO STIPULATED.
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.