Opinion
No. CR 11-686 JW
11-22-2011
UNITED STATES OF AMERICA, Plaintiff, v. SHARON WANG, HEATHER YIN, Defendants.
NOLAN, ARMSTRONG & BARTON, LLP Thomas J. Nolan, Esq. Attorney for Defendant Sharon Wang LAW OFFICES OF DORON WEINBERG Doron Weinberg Attorney for Defendant Heather Yin David Callaway Assistant United States Attorney
Thomas J. Nolan (SBN: 48413)
Nolan, Armstrong
& Barton, LLP
Attorney for Defendant
Sharon Wang
STIPULATION TO CONTINUE TRIAL
SETTING HEARING AND TO EXCLUDE
TIME; ORDER [PROPOSED]
Date: Monday, November 28, 2011
Time: 1:30 p.m.
Before The Honorable James Ware
The government, Sharon Wang, and Heather Yin stipulate to continue the Trial Setting Hearing currently scheduled for Monday, November 28, 2011 at 1:30 p.m. for approximately sixty days, until Monday, January 30, 2012. This continuance is requested for two reasons. First, the request is made in order to allow for the effective preparation of all attorneys in this case. The government has to date provided defense counsel with nearly 40,000 pages of documents. Discussions are ongoing, and the parties anticipate that additional documents will be provided to defense counsel by the government. Second, the request is made in order to insure continuity of counsel, as Ms. Wang's attorney, Thomas J. Nolan, was on an extended medical leave of absence beginning in October and lasting until November 14, 2011.
The parties accordingly stipulate that the time between November 28, 2011 and January 30, 2012 should be excluded under the Speedy Trial Act to allow for effective preparation of counsel and for continuity of counsel. See 18 U.S.C. § 3161 (h)(7)(A), 18 U.S.C. § 3161 (h)(7)(B)(i), 18 U.S.C. § 3161 (h)(7)(B)(iv).
Respectfully submitted,
NOLAN, ARMSTRONG & BARTON, LLP
Thomas J. Nolan, Esq.
Attorney for Defendant
Sharon Wang
LAW OFFICES OF DORON WEINBERG
Doron Weinberg
Attorney for Defendant
Heather Yin
David Callaway
Assistant United States Attorney
ATTESTATION PER GENERAL ORDER 45
I, Thomas J. Nolan, am the ECF User whose ID and password are being used to file this Stipulation. In compliance with General Order 45, X.B., I hereby attest that Doron Weinberg and David Callaway have concurred with this filing.
[PROPOSED] ORDER
Based upon the stipulation of the parties, and good cause appearing therefor, IT IS HEREBY ORDERED that the trial setting hearing currently scheduled to occur on Monday, November 28, 2011 at 1:30 p.m., for the captioned defendant is continued until Monday, January 30, 2012 at 1:30 p.m., and that the time between November 28, 2011 and January 30, 2012 is excluded under the Speedy Trial Act to allow for effective preparation of counsel and for continuity of counsel. See 18 U.S.C. § 3161 (h)(7)(A), 18 U.S.C. § 3161 (h)(7)(B)(i), 18 U.S.C. § 3161 (h)(7)(B)(iv).
HON. JAMES WARE
United States District Court Judge