Free Stipulation - District Court of California - California

Case 3:07-cr-00619-WHA

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Filed 10/03/2007

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SCOTT N. SCHOOLS (SC 9990) United States Attorney BRIAN J. STRETCH (CSBN 163973) Chief, Criminal Division ALLISON MARSTON DANNER (CSBN 195046) Assistant United States Attorney 450 Golden Gate Avenue, Box 36055 San Francisco, California 94102-3495 Telephone: (415) 436-7144 FAX: (415) 436-7234 Email: [email protected] Attorneys for the United States

9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN FRANCISCO DIVISION 12 UNITED STATES OF AMERICA, 13 Plaintiff, 14 v. 15 MAHER WALID KHATIB, 16 Defendant. 17 18 19 20 21 22 23 24 25 26 27 28 ) ) ) ) ) ) ) ) ) ) No. CR 07-0619 WHA STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME FROM SPEEDY TRIAL ACT CALCULATION (18 U.S.C. § 3161(h)(8)(A))

With the agreement of the parties in open court, and with the consent of defendant Maher Walid Khatib, the Court enters this order documenting exclusion of time from October 9, 2007 through October 14, 2007 under the Speedy Trial Act, 18 U.S.C. § 3161(c)(1). The parties agree, and the Court finds and holds, as follows: 1. Defendant was indicted on September 27, 2007, and he was arraigned on the

indictment on September 28, 2007. Defendant made his initial appearance before this Court on October 2, 2007. Discovery was provided by the government to the defendant on October 2, 2007. 2. At the appearance on October 2, 2007, the parties requested a status conference

for the date of October 23, 2007 in order to allow defendant to review discovery that has recently
STA Stipulation CR 07-0619 W HA

Case 3:07-cr-00619-WHA

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been provided by the government. Defense counsel will be out of town for six days during the period between October 2, 2007 and October 23, 2007. 3. Defendant agreed to an exclusion of time under the Speedy Trial Act. Failure to

grant the requested continuance would unreasonably deny defendant continuity of counsel and reasonable time necessary for effective preparation, taking into account the exercise of due diligence, in this case The Court found that the ends of justice served by excluding the six-day period from October 9, 2007 through October 14, 2007 from Speedy Trial Act calculations outweigh the best interest of the public and the defendant in a speedy trial.18 U.S.C. § 3161(h)(8)(A) & (B)(iv). 4. Accordingly, and with the consent of the defendant at the appearance on October

2, 2007, the Court ordered that the period from October 9, 2007 through October 14, 2007 be excluded from Speedy Trial Act calculations. Id. IT IS SO STIPULATED.

DATED: October 3, 2007

____________/s/________________ RONALD C. TYLER Attorney for Defendant

DATED: October 3, 2007

____________/s/________________ ALLISON MARSTON DANNER Assistant United States Attorney

IT IS SO ORDERED.

DATED: ______________

_______________________________ WILLIAM ALSUP United States District Judge

STA Stipulation CR 07-0619 W HA

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