Free Stipulation - District Court of California - California

Case 4:08-cr-00517-CW

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Filed 08/14/2008

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JOSEPH P. RUSSONIELLO (CABN 44332) United States Attorney BRIAN J. STRETCH (CABN 163973) Chief, Criminal Division WADE M. RHYNE (CABN 216799) Assistant United States Attorney 1301 Clay Street, Suite 340-S Oakland, California 94612 Telephone: (510) 637-3680 Facsimile: (510) 637-3724 E-Mail: [email protected] Attorneys for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION UNITED STATES OF AMERICA, Plaintiff, v. ALEXANDER E. SORIANO, Defendant. ) ) ) ) ) ) ) ) ) ) ) No. CR-08-0517 CW STIPULATED REQUEST TO CONTINUE HEARING DATE TO AUGUST 27, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: August 27, 2008 2:00 p.m. Hon. Claudia Wilken

The above-captioned matter is currently set on August 20, 2008 before this Court for waiver of indictment and change of plea. The parties request that this Court continue the hearing to August 27, 2008 at 2:00 p.m. and that the Court continue to exclude time under the Speedy Trial Act between August 20, 2008 and August 27, 2008. The government is completing its review of the loss totals in the above-entitled action and finalizing the terms of the plea agreement as discussed by the parties. Likewise, the defense is continuing to review discovery. Both parties require additional time to effectively prepare the case for further disposition and change of plea on August 27, 2008. Therefore, the parties stipulate and request that the Court continue to exclude time between August 20, 2008 and August 27, 2008 under the Speedy Trial Act for reasonable time necessary for counsel to
STIP. AND [PROPOSED] ORDER TO SET CONTINUE HEARING TO AUGUST 27, 2008 AND TO EXCLUDE TIME No. CR-08-0517 CW

Case 4:08-cr-00517-CW

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effectively prepare, pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv). The parties agree the ends of justice served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial.

DATED: August 14, 2008

______________________________ WADE M. RHYNE Assistant United States Attorney Counsel for United States

/S/ ____________________________ RODEL E. RODIS Counsel for Alexander E. Soriano

STIP. AND [PROPOSED] ORDER TO SET CONTINUE HEARING TO AUGUST 27, 2008 AND TO EXCLUDE TIME No. CR-08-0517 CW

Case 4:08-cr-00517-CW

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STIP. AND [PROPOSED] ORDER TO SET CONTINUE HEARING TO AUGUST 27, 2008 AND TO EXCLUDE TIME No. CR-08-0517 CW

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION UNITED STATES OF AMERICA, Plaintiff, v. ALEXANDER E. SORIANO, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) No. CR-08-0064 CW [PROPOSED] ORDER TO CONTINUE HEARING DATE TO AUGUST 27, 2008 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT Date: Time: Court: August 27, 2008 2:00 p.m. Hon. Claudia Wilken

The parties jointly requested that the hearing in this matter be continued from August 20, 2008 to August 27, 2008, and that time be excluded under the Speedy Trial Act between August 20, 2008 and August 27, 2008 to allow for the effective preparation of counsel for the reasons set forth in the parties' stipulated request. For these stated reasons, the Court finds that the ends of justice served by granting the continuance outweigh the best interests of the public and the defendant in a speedy trial. Good cause appearing therefor, and pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv), IT IS HEREBY ORDERED that this matter is set for motions setting or disposition or change of plea on August 27, 2008 at 2:00 p.m., and that time between August 20, 2008 and

Case 4:08-cr-00517-CW

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Filed 08/14/2008

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August 27, 2008 will continue to be excluded under the Speedy Trial Act to allow for the effective preparation of counsel, taking into account the exercise of due diligence.

DATED:_________________

____________________________________ HON. D. CLAUDIA WILKEN United States District Judge

STIP. AND [PROPOSED] ORDER TO SET CONTINUE HEARING TO AUGUST 27, 2008 AND TO EXCLUDE TIME No. CR-08-0517 CW