Free Stipulation - District Court of California - California

Case 3:07-cr-00619-WHA

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Filed 10/30/2007

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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 the exclusion of time from October 30, 2007 through November 27, 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. Defendant next appeared before this Court on October 23, 2007 for a status conference. 2. At the status conference on October 23, 2007, defendant asked that substitute

counsel be appointed. After hearing from defendant and his defense counsel, this Court granted
STA Stipulation CR 07-0619 W HA

Case 3:07-cr-00619-WHA

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Filed 10/30/2007

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defendant's request. The Court set the matter for a status conference with defendant's new counsel on October 30, 2007. In addition, the Court ordered time excluded under the Speedy Trial Act Calculations from October 23, 2007 through October 30, 2007. 3. At the status conference held on October 30, 2007, defendant's new counsel stated

that she had just received discovery and had not yet had an opportunity to investigate the case or to speak with her client. The parties requested that another status conference be held on November 27, 2007. In light of these facts, the Court found that the ends of justice served by excluding the period from October 30, 2007 through November 27, 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

30, 2007, the Court ordered that the period from October 30, 2007 through November 27, 2007 be excluded from Speedy Trial Act calculations. Id.

IT IS SO STIPULATED. DATED: October 30, 2007 _____________/s/_______________ JULIA JAYNE Attorney for Defendant _____________/s/_______________ ALLISON MARSTON DANNER Assistant United States Attorney

18 19 20 21 IT IS SO ORDERED. 22 23 DATED: ______________ 24 25 26 27 28
STA Stipulation CR 07-0619 W HA

DATED: October 30, 2007

_______________________________ WILLIAM ALSUP United States District Judge

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