Opinion
No. CR. S-09-179 GEB
08-31-2011
UNITED STATES OF AMERICA, Plaintiff, v. ANTHONY VASSALLO, Defendant.
BRUCE LOCKE Attorney for Anthony Vassallo For JEAN HOBLER Attorney for the United States
BRUCE LOCKE (#177787)
Moss & Locke
Attorneys for
ANTHONY VASSALLO
STIPULATION AND PROPOSED
ORDER TO CONTINUE THE
STATUS CONFERENCE FROM
SEPTEMBER 2, 2011 TO OCTOBER
28, 2011 AT 9:00 A.M.
IT IS HEREBY STIPULATED AND AGREED between the defendant, Anthony Vassallo, by and through his defense counsel, Bruce Locke, and the United States of America by and through its counsel, Assistant U.S. Attorney Jean Hobler, that the status conference scheduled for September 2, 2011 should be continued to October 28, 2011 at 9:00 a.m..
The reason for the continuance is that the case is quite complex and there is substantial discovery that must be reviewed. Defense counsel needs to review additional documents in the possession of the government. Defense counsel is advised that a substantial number of documents are in the possession of the SEC and the Receiver and that review of those documents will require travel to San Francisco. Government counsel has advised that she will soon be providing the defense counsel with a proposed plea agreement. Accordingly, the time between September 2, 2011 and, October 28, 2011 should be excluded from the Speedy Trial calculation pursuant to Title 18, United States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Ms. Hobler has authorized Mr. Locke to sign this pleading for her.
Respectfully submitted,
BRUCE LOCKE
Attorney for Anthony Vassallo
For JEAN HOBLER
Attorney for the United States
The Court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial.
IT IS SO ORDERED.
GARLAND E. BURRELL
United States District Judge