LAW OFFICES OF
WING & PARISI
A PROFESSIONAL CORPORATION
1101 E STREET
SACRAMENTO, CA 95814
ATTORNEYS FOR: DEFENDANT
AMENDED STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE FROM
AUGUST 4, 2011 AT 10:00 A.M. TO SEPTEMBER 15, 2011 AT 10:00 AM.
The parties herein, the Government, by and through its counsel, Assistant United States Attorney Todd Leras, Anita Chu, by and through her counsel, Dwight Samuel, defendant Nhat Hoang, by and through her counsel Linda M. Parisi, defendant Washing Chen, by and through his counsel, Carl Larson, defendant Winnie Chen, by and through her counsel Erin J. Radekin, defendant Sang Ly, by and through his counsel, Danny Brace, and Cuong Cach, by and through his counsel, Christopher H. Wing, have agreed and hereby stipulate to vacate the date now set for a Status Conference, August 4, 2011 at 10:00 a.m. and to continue the Status Conference to September 15, 2011 at 10:00 a.m., in courtroom #3, the courtroom of the Honorable Kimberly J. Mueller.
This request is made on the ground that defense counsel is engaged in continuing investigation of the case and is in the process of providing additional information for the government to consider as part of the resolution process.
The government and defendants agree that exclusion of time is appropriate under 18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T4 [reasonable time to prepare], and further agree that this exclusion of time includes the period from August 4, 2011 up to and including September 15, 2011 at 10:00 am. It is further agreed and stipulated that the ends of justice served in granting this request outweigh the best interests of the public and the defendants in a speedy trial.
SO STIPULATED
BENJAMIN WAGNER
United States Attorney
By: TODD LERAS
Assistant U.S. Attorney
DWIGHT SAMUEL
Attorney for Defendant ANITA CHU
LINDA M. PARISI
Attorney for Defendant Nhat Hoang
CARL LARSON
Attorney for Defendant Washing Chen
ERIN J. RADEKIN
Attorney for Defendant Winnie Chen
DANNY BRACE
Attorney for Sang Ly
CHRISTOPHER H. WING
Attorney for Defendant Cuong Cach
ORDER
For the reasons set forth in the foregoing Stipulation of Counsel, IT IS ORDERED THAT:
The Status Conference now set for August 4, 2011 at 10:00 a.m. is VACATED, and the above-captioned matter is set for Status Conference on September 15, 2011 at 10:00 a.m. in Courtroom # 3.
The Court finds excludable time in this matter through September 15, 2011 under 18 U.S.C. §3161(h)(7)(B)(iv) and Local Code T4, to allow continuity of counsel and reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court further finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(B)(iv) and Local Code T4.
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UNITED STATES DISTRICT JUDGE