Free Stipulation - District Court of California - California

Case 3:08-cr-00043-SI

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Filed 03/04/2008

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JOSEPH P. RUSSONIELLO (CASBN 44332) United States Attorney BRIAN J. STRETCH (CASBN 163973) Chief, Criminal Division JEFFREY R. FINIGAN (CASBN 168285) Assistant United States Attorney 450 Golden Gate Avenue San Francisco, California 94102 Telephone: (415) 436-7232 Facsimile: (415) 436-7234 Email: [email protected] Attorneys for Plaintiff UNITED STATES DISTRICT COURT

11 NORTHERN DISTRICT OF CALIFORNIA 12 SAN FRANCISCO DIVISION 13 14 UNITED STATES OF AMERICA, 15 Plaintiff, 16 17 18 DMITRI GLAZNIKOV, 19 Defendant. 20 21 22 23 24 25 26 27 28 The above-captioned matter came before the Court on February 29, 2008, for status. The defendant was represented by Anthony Brass, Esq., and the government was represented by Wendy Thomas, Assistant United States Attorney. The matter was continued to March 21, 2008, at 11:00 a.m. in this Court for further proceedings. The Court made a finding that the time from and including February 29, 2008, through March 21, 2008, should be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(8)(A), because the ends of justice served by taking such action outweighed the best interest of the public
STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME CR 08-0043 SI

v.

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Criminal No. CR 08-0043 SI

STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME

Case 3:08-cr-00043-SI

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and the defendant in a speedy trial. The finding was based on the need for the defendant to have reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and for continuity of counsel pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv). The parties hereby agree to and request that the case be continued until March 21, 2008, and that the exclusion of time until then be granted. The parties agree and stipulate that the additional time is appropriate and necessary under Title 18, United States Code, § 3161(h)(8)(A), because the ends of justice served by this continuance outweigh the best interest of the public and the defendant in a speedy trial. This time exclusion will allow defense counsel to effectively prepare, taking into account the exercise of due diligence, and will provide for continuity of counsel for the defendant.

DATED: March 4, 2008

/s/ ANTHONY BRASS Counsel for Dmitri Glaznikov

DATED: March 4, 2008

/s/ JEFFREY FINIGAN Assistant U.S. Attorney

So ordered. DATED: SUSAN ILLSTON UNITED STATES DISTRICT COURT JUDGE

STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME CR 08-0043 SI

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 X Law Office of Anthony J. Brass 3223 Webster St San Francisco, CA 94123

CERTIFICATE OF SERVICE The undersigned hereby certifies that he is an employee of the office of the United States Attorney, Northern District of California and is a person of such age and discretion to be competent to serve papers. The undersigned certifies that he caused copies of STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME in the case of U.S. v. DMITRI GLAZNIKOV, No. CR-08-0043 SI to be served on the parties in this action, addressed as follows which are the last known addresses:

(By Personal Service), I caused such envelope to be delivered by hand to the person or offices of each addressee(s) above. (By Facsimile), I caused each such document to be sent by Facsimile to the person or offices of each addressee(s) above. (By Mail), I caused each such envelope, with postage thereon fully prepaid, to be placed in the United States mail at San Francisco, California. (By Fed Ex), I caused each such envelope to be delivered by FED EX to the address listed above. I declare under penalty of perjury that the foregoing is true and correct. March 4, 2008 ______________/s/_____________ WILSON WONG United States Attorney's Office