Opinion
CASE NO. 1:11-mj-00088 SKO
01-25-2012
ROBERT A. CASSIO SBN: 170197 Law Office of Robert A. Cassio Attorney for Defendant THAI SEE
ROBERT A. CASSIO SBN: 170197
Law Office of Robert A. Cassio
Attorney for Defendant THAI SEE
STIPULATION TO CONTINUE MOTIONS
SCHEDULE; ORDER THEREON
Date: March 22, 2012
Time: 10:00 a.m.
Dept.: 9
Honorable Dennis L. Beck
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, that a new motions schedule be set, however, the hearing on motions currently scheduled for March 22, 2012, at 10:00 a.m. before the Honorable Dennis L. Beck remain as scheduled. The requested new motions schedule is as follows:
+-----------------------------------------------------+ ¦Event: ¦Present Date: ¦Requested New Date: ¦ +-------------+-----------------+---------------------¦ ¦Motions Due ¦December 16, 2011¦February 9, 2012 ¦ +-------------+-----------------+---------------------¦ ¦Replies Due ¦January 20, 2012 ¦March 1, 2012 ¦ +-------------+-----------------+---------------------¦ ¦Responses Due¦February 10, 2012¦March 8, 2012 ¦ +-----------------------------------------------------+
The continuance is requested by counsel for the Defendant to allow the parties additional time to attempt to investigate, confer and potentially resolve this matter. New counsel for the Government has recently been assigned and it is possible that the parties may be able to resolve the matter without the necessity of motions. The revised schedule has been discussed and agreed to by Special Assistant United States Attorney Wallace J. Lee and Attorney Robert A. Cassio. The requested continuance will conserve time and resources for all parties and the Court.
The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for further defense preparation pursuant to 18 U.S.C. §§3161(h)(7)(A) and (B) in that the ends will be served by a continuance.
BENJAMIN B. WAGNER
United States Attorney
_____________________
WALLACE J. LEE
Special Assistant U.S. Attorney
This was agreed to by Mr. Lee via email on January 24, 2012
_____________________
ROBERT A. CASSIO
Attorney for Defendant
THAI SEE
IT IS SO ORDERED.
Dennis L. Beck
UNITED STATES MAGISTRATE JUDGE