Opinion
No. 2:11-CR-00211-MCE
01-23-2012
BENJAMIN B. WAGNER
United States Attorney
MICHAEL M. BECKWITH
Assistant U.S. Attorney
STIPULATION AND ORDER RESETTING STATUS CONFERENCE, AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT
The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Michael M. Beckwith, Assistant United States Attorney, defendant Masod John Rahimi, through his counsel of record, Gina Tennen, and Monsore Rahimi, through his counsel of record, Vitaly B. Segal, request that the status conference set for January 26, 2012, be continued to March 22, 2012, at 9:00 a.m. and stipulate that the time beginning January 26, 2012, and extending through March 22, 2012, should be excluded from the calculation of time under the Speedy Trial Act. The parties submit that the ends of justice are served by the Court excluding such time, so that counsel for each defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4.
The parties are still in the process of discussing and negotiating the various plea offers in this case. Each defendant will need time to consider his offer in light of the additional discovery. As such, the parties need additional time to prepare.
IT IS SO STIPULATED.
BENJAMIN B. WAGNER
United States Attorney
By: ___________________________
MICHAEL M. BECKWITH
Assistant U.S. Attorney
Attorney for Plaintiff
By: ___________________________
GINA TENNEN
Attorney for Defendant
MASOD JOHN RAHIMI
By: ___________________________
VITALY B. SEGAL
Attorney for Defendant
MONSORE RAHIMI
ORDER
UPON GOOD CAUSE SHOWN and by stipulation of all parties, it is hereby ordered that this matter be set for further status conference as set forth above.
The interests of justice in granting this reasonable request for a continuance outweighs the best interests of the public and defendants for a speedy trial in this case, corresponding to Local Code T-4 (to allow defense counsel time to prepare). The Court therefore finds excludable time as set forth above to and including March 22, 2012.
IT IS SO ORDERED.
___________________________
MORRISON C. ENGLAND, JR.
UNITED STATES DISTRICT JUDGE