Opinion
No. 11-CR-00037-JAM
01-04-2012
UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL GIANG, Defendant.
JOHN BALAZS, Bar No. 157287 Attorney At Law Attorney for Defendant MICHAEL GIANG BENJAMIN B. WAGNER United States Attorney HEIKO P. COPPOLA Assistant U.S. Attorney
JOHN BALAZS, Bar No. 157287
Attorney At Law
Attorney for Defendant
MICHAEL GIANG
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE
AND EXCLUDE TIME
Date: March 6, 2012
Time: 9:30 a.m.
Hon. John A. Mendez
The parties jointly request that the status conference in this case be continued from January 10, 2012 to March 6, 2012 at 9:30 a.m. They stipulate that the time between January 10, 2012 and March 6, 2012 should be excluded from the calculation of time under the Speedy Trial Act.
The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into the account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Specifically, defense counsel needs additional time to review the discovery provided by the government, to discuss that discovery with the defendant, and to finalize a plea agreement with the government. Moreover, defense counsel has oral argument scheduled in San Francisco in the Ninth Circuit Court of Apeals on the date of the currently-scheduled status conference, January 10, 2012. For these reasons, the parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).
Respectfully submitted,
_________________________
JOHN BALAZS
Attorney for Defendant
MICHAEL GIANG
BENJAMIN B. WAGNER
United States Attorney
By: _________________________
HEIKO P. COPPOLA
Assistant U.S. Attorney
ORDER
IT IS SO ORDERED.
_________________________
HON. JOHN A. MENDEZ
U.S. District Court Judge