1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

JOSEPH P. RUSSONIELLO (CSBN 44332)

United States Attorney

BRIAN J. STRETCH (CSBN 163973)

Chief, Criminal Division

ADAM A. REEVES (NYSB 2363877)

TIMOTHY J. LUCEY (CSBN 172332)

Assistant United States Attorneys

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102

Telephone: (415) 436-7157 (AUSA Reeves)

Telephone: (415) 436-7252 (AUSA Lucey)

Facsimile: (415) 436-7234

Adam.Reeves@usdoj.gov

Timothy.Lucey@usdoj.gov

Attorneys for Plaintiff

UNITED STATES OF AMERICA

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

MAHER FAYEZ KARA, et al., 

Defendants.

 

)

)

)

)

)

)

)

)

)

)

)

Case No. CR 09 – 0417 MHP

STIPULATION AND [PROPOSED]

ORDER

WHEREAS, the government produced approximately 880,000 documents and other

materials to counsel for the defendants and defendants’ counsel believes that additional time is

necessary to review the evidence and pursue resolution of the case prior to setting a trial date;

WHEREAS, a failure to grant the continuance would deny defense counsel the reasonable

time necessary for effective preparation, taking into account the exercise of due diligence, and

under the circumstances the ends of justice served by a reasonable continuance outweigh the best

United States v. Kara, et al., [CR 09 - 0417 MHP]

STIPULATION AND[ PROPOSED] ORDER

Case 3:09-cr-00417-EMC Document 82 Filed 06/22/10 Page 1 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

interest of the public and the defendants in a speedy trial;

WHEREAS, the defendants all consent to a continuation of this case for the above

reasons and all consent to the exclusion of time from June 21, 2010 until August 2, 2010;

THEREFORE, it is hereby stipulated by and between the parties, through their respective

counsel of record, that the period of time from June 21, 2010 until August 2, 2010, shall be

excluded in computing the time within which the trial of the offense alleged in the Indictment

must commence under Title 18, United States Code, Section 3161.

The parties respectfully request that the Court vacate the status hearing currently

scheduled for 10:00 a.m. on June 25, 2010, and reschedule this matter for a Trial and Motions

Setting Conference on Monday, August 2, 2010 at 10:00 a.m.

DATED: June 16, 2010 JOSEPH P. RUSSONIELLO

United States Attorney

 /S/ 

TIMOTHY J. LUCEY 

Assistant United States Attorney

DATED: June 16, 2010 /S/ 

Carl H. Loewenson, Jr.

George C. Harris, Esq.

MORRISON & FOERSTER, LLP

Counsel for Maher Kara

DATED: June 16, 2010 /S/ 

Miles Ehrlich, Esq.

Ismail Ramsey, Esq.

RAMSEY & EHRLICH LLP

Counsel for Mounir Kara

DATED: June 16, 2010 /S/ 

William H. Green, Esq.

Counsel for Emile Jilwan

United States v. Kara, et al., [CR 09 - 0417 MHP]

STIPULATION AND[ PROPOSED] ORDER

2

Case 3:09-cr-00417-EMC Document 82 Filed 06/22/10 Page 2 of 3
1

2

3

4

5

6

7

8

9

10

11

12

13

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

On the basis of material submitted to the Court, IT IS HEREBY ORDERED:

The Court finds that the ends of justice served by granting a continuance from June 21,

2010, until August 2, 2010, outweigh the best interests of the public and the defendants in a

speedy trial and in the prompt disposition of criminal cases. The Court therefore concludes that

this exclusion of time from June 21, 2010, until August 2, 2010, should be made under Title 18,

United States Code, Sections 3161(h)(7)(B)(iv).

The Court vacates the status hearing currently scheduled for 10:00 a.m. on June 25,

2010, and reschedules this matter for a Trial and Motions Setting Conference on 

Monday, August 2, 2010, at 10:00 a.m.

IT IS SO ORDERED.

 

DATED: _____________________________

HON. MARILYN HALL PATEL

Northern District of California

United States v. Kara, et al., [CR 09 - 0417 MHP]

STIPULATION AND PROPOSED ORDER

3

June 21, 2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:09-cr-00417-EMC Document 82 Filed 06/22/10 Page 3 of 3