From Casetext: Smarter Legal Research

United States v. Bagdasarian

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
Apr 12, 2012
CASE NO. 1:11-CR-352 LJO SKO (E.D. Cal. Apr. 12, 2012)

Opinion

CASE NO. 1:11-CR-352 LJO SKO

04-12-2012

UNITED STATES OF AMERICA, Plaintiff, v. MARK BAGDASARIAN and RYAN BAGDASARIAN Defendants.

BENJAMIN B. WAGNER United States Attorney ELANA S. LANDAU Assistant U.S. Attorney


BENJAMIN B. WAGNER

United States Attorney

ELANA S. LANDAU

Assistant U.S. Attorney

STIPULATION AND ORDER TO

EXCLUDE TIME

The parties request that the status conference in this case be continued from April 16, 2012 to June 4, 2012 at 1:00p.m. They stipulate that the time between April 16, 2012 and June 4, 2012 should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation and to allow for plea negotiations, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). Specifically, the government has provided substantial additional discovery related to financial crimes which may result in additional charges and therefore impact plea negotiations in this case. The government has not yet made a plea offer due to the potential for additional charges against one or more of the defendants. The continuance will provide sufficient time for the government to execute a plea offer and for counsel for the defendants to present the government's proposed plea offer to their respective clients for consideration. The parties stipulate and agree that the interests 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).

Respectfully Submitted,

BENJAMIN B. WAGNER

United States Attorney

By: _________________________

ELANA S. LANDAU

Assistant U.S. Attorney

_________________________

ANTHONY P. CAPOZZI

Attorney for Mark Bagdasarian

_________________________

JEREMY S. KROGER

Attorney for Ryan Bagdasarian

ORDER

IT IS SO ORDERED.

Sheila K. Oberto

UNITED STATES MAGISTRATE JUDGE


Summaries of

United States v. Bagdasarian

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
Apr 12, 2012
CASE NO. 1:11-CR-352 LJO SKO (E.D. Cal. Apr. 12, 2012)
Case details for

United States v. Bagdasarian

Case Details

Full title:UNITED STATES OF AMERICA, Plaintiff, v. MARK BAGDASARIAN and RYAN…

Court:UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA

Date published: Apr 12, 2012

Citations

CASE NO. 1:11-CR-352 LJO SKO (E.D. Cal. Apr. 12, 2012)