Opinion
CASE NO. 1:11-CR-352 LJO SKO
04-12-2012
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