Opinion
Case No: 11-CR-428 GEB
01-25-2012
UNITED STATES OF AMERICA, Plaintiff, v. SMITH et al. Defendants.
BENJAMIN B. WAGNER United States Attorney By: WILLIAM E. BONHAM for RICHARD BENDER Assistant U.S. Attorney By: WILLIAM E. BONHAM for MARK REICHEL Counsel for Defendant Bryan Smith By: WILLIAM E. BONHAM for STEVEN BAUER Counsel for Defendant Kelly Smith DANIEL J. BRODERICK Federal Defender WILLIAM E. BONHAM for TIMOTHY ZINDEL Assistant Federal Defender Attorney for Defendant Daniel Goldsmith By: WILLIAM E. BONHAM for WILLIAM E. BONHAM Counsel for Defendant Bruce Goldsmith By: WILLIAM E. BONHAM for MICHAEL E. HANSEN Counsel for Defendant Robert Klaus By: WILLIAM E. BONHAM for A. STANLEY KUBOCHI Counsel for Defendant Ryder Phillips
William E. Bonham, SB# 55478
Hotel de France Bldg., Old Sacramento
Attorney for: Bruce Goldsmith
STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE
The defendants, Bryan Smith, Kelly Smith, Daniel Goldsmith, Bruce Goldsmith, Robert Klaus and Ryder Phillips, by and through their undersigned counsels, and the United States, through its undersigned counsel, hereby agree and request the status conference currently set for Friday, January 27, 2012 at 9:00 am be vacated and continued until Friday, March 9, 2012 at 9:00 am.
This continuance is requested because plea offers were recently sent out by the government and defense counsel needs additional time to review the offers, continue review of the voluminous discovery and meet with their respective clients, with an emphasis on determining whether to accept the offers.
The parties stipulate that time should be excluded under the Speedy Trial Act due to the needs of counsel for continued case preparation. Local Code T4 & 18 U.S.C § 3161 (h)(7)(B)(iv).
I, William E. Bonham, the filing party, have received authorization from AUSA Bender and co-counsel to sign and submit this stipulation and proposed order on their behalf.
Accordingly, the defense and the United States stipulate that the status conference for defendants Bryan Smith, Kelly Smith, Daniel Goldsmith, Bruce Goldsmith, Robert Klaus and Ryder Phillips, should be continued until Friday, March 9, 2011 at 9:00 am. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and defendant in a Speedy Trial. 18 U.S.C. § 3161(h)(7)(A).
BENJAMIN B. WAGNER
United States Attorney
By:WILLIAM E. BONHAM for
RICHARD BENDER
Assistant U.S. Attorney
By: WILLIAM E. BONHAM for
MARK REICHEL
Counsel for Defendant Bryan Smith
By: WILLIAM E. BONHAM for
STEVEN BAUER
Counsel for Defendant Kelly Smith
DANIEL J. BRODERICK
Federal Defender
WILLIAM E. BONHAM for
TIMOTHY ZINDEL
Assistant Federal Defender
Attorney for Defendant Daniel Goldsmith
By: WILLIAM E. BONHAM for
WILLIAM E. BONHAM
Counsel for Defendant Bruce Goldsmith
By: WILLIAM E. BONHAM for
MICHAEL E. HANSEN
Counsel for Defendant Robert Klaus
By: WILLIAM E. BONHAM for
A. STANLEY KUBOCHI
Counsel for Defendant Ryder Phillips
ORDER
IT IS SO ORDERED THAT THE status conference for defendants Bryan Smith, Kelly Smith, Daniel Goldsmith, Bruce Goldsmith, Robert Klaus and Ryder Phillips currently set for Friday, January 27, 2012 at 9:00 am is vacated and re-set to Friday, March 9, 2012 at9:00 am.
I find that the continuance is necessary due to the needs of counsel for continued case preparation. Accordingly, time is excluded under the Speedy Trial Act from January27, 2012 up to and including March 9, 2012, pursuant to Local Code T4 and 18 U.S.C. § 3161(h)(7)(B)(iv). I find that the ends ofjustice served by granting this continuance outweigh the best interest of the public and defendant in a speedy trial. 18 U.S.C. § 3161(h) (7)(A).
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GARLAND E. BURRELL JR.
United States District Judge