Opinion
No. CR 12-0467 RS
04-18-2013
MELINDA HAAG United States Attorney DAMALI A. TAYLOR Assistant United States Attorney MICHAEL STEPANIAN Counsel for ALIK D. ILYIN
MELINDA HAAG (CABN 132612)
United States Attorney
MIRANDA KANE (CABN 150630)
Chief, Criminal Division
DAMALI A. TAYLOR (262489)
Assistant United States Attorney
450 Golden Gate Ave., Box 36055
San Francisco, California 94102
Telephone: (415) 436-7200
Fax: (415) 436-7234
E-Mail: damali.taylor@usdoj.gov
Attorneys for Plaintiff
STIPULATION AND [PROPOSED]
ORDER CONTINUING TRIAL DATE
AND DOCUMENTING EXCLUSION OF
TIME UNDER SPEEDY TRIAL ACT
On April 17, 2013, the parties and the Court agreed to continue the jury trial in this matter, presently set for May 28, 2013, to June 24, 2013 before the Honorable Richard Seeborg.
Counsel for defendant ALIK D. ILYIN, Michael Stepanian, and the government, represented by DAMALI A. TAYLOR, Assistant United States Attorney, hereby agree and stipulate, for both continuity and effective preparation of counsel, that time be excluded under the Speedy Trial Act until Monday, June 24, 2013, the date for trial. The additional time is necessary to give counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence, and it is in the best interests of the defendant to do so. The parties agree that the ends of justice served by granting such an exclusion of time outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A). SO STIPULATED:
MELINDA HAAG
United States Attorney
______________________
DAMALI A. TAYLOR
Assistant United States Attorney
______________________
MICHAEL STEPANIAN
Counsel for ALIK D. ILYIN
[PROPOSED] ORDER
For the foregoing reasons, the Court concludes that an exclusion of time through and including June 24, 2013, should be made under Title 18, United States Code, Sections 3161(h)(7)(A) and 3161(h)(7)(B)(iv). The Court also finds that the ends of justice served by excluding time through and including June 24, 2013 outweigh the best interest of the public and the defendant in a speedy trial. Id. § 3161(h)(7)(A).
IT IS SO ORDERED.
______________________
RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE