Case 2:13-cr-00082-KJM Document 33 Filed 03/24/14 Page 1 of 2

1 JASON S. LEIDERMAN, SBN 203336 jay@criminal-lawyer.me 2 ERIC J. LINDGREN, SBN 288542 eric@criminal-lawyer.me 3 LAW OFFICES OF JAY LEIDERMAN 5740 Ralston Street, Suite 300 California 93003 4 Ventura, Tel: 805-654-0200 Fax: 805-654-0280 5 TOR EKELAND, PRO HAC VICE 6 tor@torelekand.com TOR EKELAND, P.C. 7 155 Water Street Brooklyn, NY 11201 8 Tel: 718-285-9279 Fax: 718-504-5417 9 Attorneys for Defendant 10 MATTHEW KEYS 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Defendant Matthew Keys, by and through his counsel of record, and plaintiff United States of America (“the government”), by and through its counsel of record, hereby stipulate as follows: 1. The status conference currently scheduled for Wednesday, March 26, 2013, should be v. MATTHEW KEYS, Defendant. UNITED STATES OF AMERICA, Plaintiff, CASE NO. 2:13-CR-82 KJM STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA

25 removed from the Court’s calendar and continued one week until to April 2, 2013 at 9:00 a.m.. 26 2. Defendant is represented by Mr. Leiderman and Mr. Lindgren of Ventura, CA and

27 Mr. Ekeland of Brooklyn, New York. Due to the distance from court and the travel plans that are 28 required to attend, along with other obligations on defense counsel’s schedule, defense counsel are 1 Stipulation and [Proposed] Order to 29
Continue Status and Exclude Time

30

Case 2:13-cr-00082-KJM Document 33 Filed 03/24/14 Page 2 of 2

th 1 not reasonably available on the 26 of March. The Assistant United States Attorney has scheduled

2 leave and is unavailable on March 26, 2014. 3 3. Defendant is in the process of assessing which additional discovery is required and

4 expects to send a letter requesting such discovery to the government in the next few days. Defendant 5 will be continuing to analyze the substantial amount of discovery in this matter, which discovery 6 includes extensive logs from the entity described as the victim in the indictment. Several different 7 attorneys and support staff are actively engaged in this task. 8 4. The short time between March 19, 2014 and April 2, 2014 should be excluded from

9 the computation of time under the Speedy Trial Act. The ends of justice served by granting this 10 continuance outweigh the best interest of the public and Defendant in a speedy trial. 18 U.S.C. § 11 3161(h)(7)(A). In light of the facts set forth in ¶ 2 and 3, failure to grant this continuance would 12 unreasonably deny counsel reasonable time necessary for effective preparation, taking into account 13 the exercise of due diligence, and would unreasonably deny the government and the defendant 14 continuity of counsel. 18 U.S.C. § 3161(h)(7)(B)(iv). 15 Dated: March 24, 2014 16 17 18 Dated: March 24, 2014 19 20 Dated: March 24, 2014 21 22 23 Counsel for Defendant 24 SO ORDERED. 25 26 Dated: 27 28 29 30
Stipulation and [Proposed] Order to Continue Status and Exclude Time

/s/ Jay Leiderman JAY LEIDERMAN TOR EKELAND /s/ Matthew D. Segal MATTHEW D. SEGAL Assistant United States Attorney /s/ James A. Silver JAMES A. SILVER Trial Attorney

_______________________________ HON. KIMBERLY J. MUELLER UNITED STATES DISTRICT JUDGE 2

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