Opinion
No. CR. S-11-054 GEB
10-06-2011
UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL BOLDEN, et al., Defendants.
BRUCE LOCKE Attorney for Victor Alvarado For DOUGLAS BEEVERS Attorney for Christopher Jackson For TIM WARRINER Attorney for Michael Bolden For MICHAEL CHASTAINE Attorney for Erica Arceo For JAY TONEY Attorney for Nicholo Arceo For MATT SEGAL Attorney for the United States
BRUCE LOCKE (#177787)
Moss & Locke
Attorneys for
VICTOR ALVARADO
STIPULATION TO CONTINUE STATUS
CONFERENCE AND EXCLUDE TIME
UNDER SPEEDY TRIAL ACT
IT IS HEREBY STIPULATED AND AGREED between the defendants, Michael Bolden, Christopher Jackson, Victor Alvarado, Erica Arceo, and Nicholo Arceo, by and through their undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Matthew Segal, that the status conference presently set for October 7, 2011 at 9:00 a.m., should be continued to January 13, 2012 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from October 7, 2011 through January 13, 2012.
The reason for the continuance is that the defendants need additional time to diligently continue their investigation and preparation of the matter for trial. 18 U.S.C. § 3161(h)(7)(B)(iv). There is substantial discovery and the issues are complicated. The government represents that its evidence includes over one hundred interview memoranda and over fifteen boxes of documents. Thus, counsel for all parties have arranged to meet at the FBI on October 13, 2011 to view the evidence and develop a reasonable plan for the defense to access the discovery and obtain copies, in a mutually agreeable format, of what documents are relevant and discoverable. After that, the Government intends to disclose discovery according to plan and the defense intends to review and analyze it. Accordingly, the time between October 7, 2011 and January 13, 2012 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Segal and the undersigned defense counsel have authorized Mr. Locke to sign this pleading for them.
BRUCE LOCKE
Attorney for Victor Alvarado
For DOUGLAS BEEVERS
Attorney for Christopher Jackson
For TIM WARRINER
Attorney for Michael Bolden
For MICHAEL CHASTAINE
Attorney for Erica Arceo
For JAY TONEY
Attorney for Nicholo Arceo
For MATT SEGAL
Attorney for the United States
The Court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial.
IT IS SO ORDERED.
GARLAND E. BURRELL JR.
United States District Judge