Opinion
No. 11-CR-00037-JAM
07-11-2012
JOHN BALAZS 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: August 7, 2012
Hon. John A. Mendez
The parties jointly request that the status conference in this case be continued from July 17, 2012 to August 7, 2012 at 9:45 a.m. They stipulate that the time between July 17, 2012 and August 7, 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 and analyze documents provided by the government, to consult with the defendant, and to finalize a plea agreement with the government. Moreover, defense counsel has oral argument in a Ninth Circuit appeal on July 17, 2012, at 9:00 a.m. 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