Opinion
No. 2:12-CR-0066 GEB
07-13-2012
KELLY BABINEAU (CA State Bar #190418) The Law Office of Kelly Babineau Attorney for ALLA SAMCHUK
KELLY BABINEAU (CA State Bar #190418)
The Law Office of Kelly Babineau
Attorney for ALLA SAMCHUK
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE STATUS
CONFERENCE
Judge: Hon. Garland E. Burrell
It is hereby stipulated between the parties, Michael Anderson, Assistant United States Attorney, Kelly Babineau, attorney for defendant Alla Samchuk, that the status conference date of July 12, 2012, should be continued until August 3, 2012. The continuance is necessary to complete the review of discovery, and defense investigation. All counsel are continuing to engage in negotiations with the government.
IT IS STIPULATED that the period of time from the signing of this Order up to and including the new status conference date of August 3, 2012, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, for ongoing preparation of counsel.
Respectfully submitted,
____________________________
KELLY BABINEAU
Attorney for Alla Samchuk
Michael Anderson
Kelly Babineau for:
MICHAEL ANDERSON
Assistant U.S. Attorney
KELLY BABINEAU (CA State Bar #190418)
The Law Office of Kelly Babineau
Attorney for ALLA SAMCHUK
THE UNITED STATES OF AMERICA, Plaintiff,
v.
ALLA SAMCHUK Defendant.
No. 2:12-CR-0066 GEB
[PROPOSED] ORDER
Judge: Hon. Garland E. Burrell
UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for July 12, 2012, at 9:00 a.m. be continued to August 3, 2012, at 9:00 a.m. Based on the representations of counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account due diligence. The continuance outweighs the best interests of the public and the defendants to a speedy trial. It is ordered that time from this date to August 3, 2012, shall be excluded from computation of the time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7) and Local Codq T4, to allow counsel time to prepare.
____________________________
GARLAND E. BURRELL, JR.
Senior United States District Judge