Opinion
No. 2:06-cr-0035-MCE.
February 16, 2006
MARK J. REICHEL, Bar #155034, Attorney At Law, Sacramento, California, Attorney for Defendant, ERIC McDAVID.
DAVID W. DRATMAN, ESQ., Attorney for Lauren Weiner.
CHRIS HAYDENMEYER, ESQ., Attorney for Zach Jensen.
McGREGOR W. SCOTT, United States Attorney.
ELLEN V. ENDREZZI, Assistant U.S. Attorney. Attorney for Plaintiff.
STIPULATION TO CONTINUE STATUS CONFERENCE DATE; ORDER THEREON
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, ELLEN V. ENDREZZI, Assistant United States Attorney, attorney for Plaintiff, and MARK J. REICHEL, Esq., attorney for defendant McDAVID, DAVID W. DRATMAN, Esq., local counsel for defendant WEINER, CHRISTOPHER HAYDENMEYER, Esq., attorney for defendant Jenson, that the present date for the status hearing of February 14, 2006 be vacated and re calendared for March 7, 2006.
This continuance is requested as all defense counsel need adequate time to prepare for the case. All defense counsel have received a large number of audio tape recordings as well as video tape recordings of the undercover investigation. Defense counsel desire to review discovery in preparation and investigation of the case. Additional legal research also needs to be performed and defense counsel may have to obtain and review pertinent records.
Accordingly, all counsel and defendants agree that time under the Speedy Trial Act from the date this stipulation is lodged, through March 7, 2006, should be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to Title 18 U.S.C. § 3161(H)(8)(B)(iv) and Local Code T4.