Opinion
US v. SHAVLOVSKY, Dist. Court, ED California 2015
ERIN J. RADEKIN, Attorney at Law, Sacramento, California, Attorney for Defendant, ANGELA SHAVLOVSKY.
BENJAMIN WAGNER, United States Attorney, JILL THOMAS, Assistant United States Attorney.
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE
TROY L. NUNLEY, District Judge.
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, May 21, 2015 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to July 30, 2015 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.
The reason for this request is that additional time is needed by Ms. Radekin to complete review of discovery, for investigation, and for other defense preparation. Additional discovery has been provided by the government in the last two weeks, so that discovery is currently through bates no. 72861. Further, investigation has been delayed because Ms. Radekin's investigator-of-choice for this matter has been occupied with trial preparation and jury trial in another mortgage fraud case. The Court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.
The parties further agree and stipulate that the time period from the filing of this stipulation until July 30, 2015 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation.
IT IS SO STIPULATED
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of May 21, 2015 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on July 30, 2015 at 9:30 a.m. The Court finds excludable time in this matter through July 30, 2015 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).
IT IS SO ORDERED.