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JOSEPH P. RUSSONIELLO (CABN 44332)

United States Attorney

BRIAN J. STRETCH (CABN 163973)

Chief, Criminal Division

CHRISTINE Y. WONG (NYBN 3988607)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102

Telephone: (415) 436-7301

Facsimile: (415) 436-6753

E-Mail: Christine.Wong@usdoj.gov

Attorneys for the United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA

v.

DONALD DANIELS, et al.,

Defendants.

 

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No. 09-0862 MHP

STIPULATED REQUEST CONTINUING

STATUS CONFERENCE AND WAIVING

TIME

On November 16, 2009, defendants Donald Daniels, Martin William Washburn, Irina

Rebegeneau, Sergei Shkurkin and Tapani Koivunen appeared the Honorable Marilyn H. Patel for

a trial setting hearing. The Court ordered that the parties next appear on January 25, 2010, for a

status conference. The parties request that this Court vacate that date and set this matter for

status conference on March 22, 2009, at 10:00 a.m., and that the Court exclude time under the

Speedy Trial Act between the date of this stipulation and March 22, 2009. 

The parties make this request because defense counsel and the Government are

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continuing to conduct investigation of the matter, including preparing and reviewing voluminous

discovery, and the parties would require additional preparation time in order to provide effective

assistance of counsel. 

With the agreement of the parties and with the consent of the defendants, the Court enters

this order confirming the exclusion of time under the Speedy Trial Act from January 25, 2010,

through March 22, 2010. The parties agree and stipulate, and the Court finds and holds, as

follows:

The ends of justice served by excluding the period from January 25, 2010, through March

22, 2010 from Speedy Trial Act calculations outweighs the interests of the public and the

defendants in a speedy trial, by ensuring the effective preparation of counsel, in accordance with

18 U.S.C. § 3161(h)(8)(A) and (B).

STIPULATED:

DATED: January 21, 2010 /s Mary McNamara 

MARY MCNAMARA, ESQ.

Attorney for DONALD DANIELS

DATED: January 21, 2010 /s Nanci Clarence 

NANCI CLARENCE, ESQ.

Attorney for MARTIN WILLIAM WASHBURN

DATED: January 21, 2010 /s Anthony Brass 

ANTHONY BRASS, ESQ.

Attorney for IRINA REBEGENEAU

DATED: January 21, 2010 /s Harry Singer 

HARRY SINGER, ESQ.

Attorney for TAPANI KOIVUNEN

DATED: January 21, 2010 /s William J. Portanova 

WILLIAM J. PORTANOVA, ESQ.

Attorney for SERGEI SHKURKIN

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DATED: January 21, 2010 /s Christine Y. Wong 

CHRISTINE Y. WONG

Assistant United States Attorney

IT IS SO ORDERED.

DATED: January __, 2010 

HON. MARILYN H. PATEL

United States District Judge

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U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Marilyn H. Patel

Case 3:09-cr-00862-MHP Document 81 Filed 01/22/10 Page 3 of 3