Opinion
No. 11-CR-00037-JAM
09-15-2011
UNITED STATES OF AMERICA, Plaintiff, v. MICHAEL GIANG, Defendant.
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 for Defendant
MICHAEL GIANG
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE
AND EXCLUDE TIME
Time: 9:30 a.m.
Hon. John A. Mendez
The parties jointly request that the status conference in this case be continued from September 20, 2011 to November 8, 2011 at 9:30 a.m. They stipulate that the time between September 20, 2011 and November 8, 2011 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 perform investigation. 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
heiko p. Coppola
Assistant U.S. Attorney
ORDER
IT IS SO ORDERED.
HON. JOHN A. MENDEZ
U.S. District Judge