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STIPULATION AND [Proposed] ORDER 

CONTINUING HEARING AND EXCLUDING TIME 

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Mark R. Vermeulen [CSBN 115381] 

Law Office of Mark R. Vermeulen 

755 Florida Street #4 

San Francisco, CA 94110.2044 

Phone: 415.824.7533 

Fax: 415.824.4833 

vermeulen@mindspring.com 

Attorney for Defendant 

WEN BING LEI 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

UNITED STATES OF AMERICA, 

 Plaintiff, 

 v. 

WEN BING LEI, 

 Defendant. 

No. 15-cr-71548-SK 

STIPULATION AND [Proposed] ORDER TO 

CONTINUE HEARING AND TO EXCLUDE 

TIME

Date: March 30, 2016 

Time: 9:30 a.m.

Court: Hon. Joseph C. Spero 

This matter is set for a preliminary hearing or return of an indictment before this Court on March 

30, 2016. The parties request that this matter be continued to May 5, 2016 at 9:30 a.m. for further 

setting. Pursuant to Fed. R. Crim. P. 5.1(d), the defendant consents to extending the time limits set forth 

in Fed. R. Crim. P. 5.1(c) to exclude from the 14-day limit the time from March 30, 2016 to the newly 

proposed hearing date (i.e., May 5, 2016) to accommodate this request, and defense counsel is 

continuing to review discovery, to conduct investigation, and to otherwise prepare the defense. As a 

result, the parties request that the Court exclude time between March 30, 2016 and May 5, 2016 for 

effective preparation of defense counsel, taking into account the exercise of due diligence, and pursuant 

to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). The extension is not sought for delay, and the parties agree 

/ / / 

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STIPULATION AND [Proposed] ORDER 

CONTINUING HEARING AND EXCLUDING TIME 

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that the ends of justice served by granting the continuance outweigh the best interests of the public and 

the defendant in a speedy trial. 

Dated: March 15, 2016 Brian J. Stretch 

Acting United States Attorney 

/S/ 

William Frentzen 

Assistant United States Attorney 

Dated: March 15, 2016 /S/ 

Mark R. Vermeulen 

Attorney for Defendant 

WEN BING LEI 

ORDER 

IT IS HEREBY ORDERED that this matter is continued to May 5, 2016 at 9:30 a.m. for further 

setting. 

IT IS FURTHER ORDERED that pursuant to Fed. R. Crim. P. 5.1(d), the 14-day limit set forth 

in Fed. R. Crim. P. 5.1(c) shall be extended, such that the 14-day limit shall run from May 5, 2016. 

IT IS FURTHER ORDERED that time between March 30, 2016 and May 5, 2016 is excluded 

pursuant to the Speedy Trial Act for effective preparation of defense counsel, taking into account the 

exercise of due diligence, and pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). Based upon the 

parties’ stipulation, the Court finds that the extension is not sought for delay, and the ends of justice 

served by granting the continuance outweigh the best interests of the public and the defendant in a 

speedy trial. 

IT IS SO ORDERED. 

Dated: March __, 2016 _____________________________ 

JOSEPH C. SPERO 

United States Magistrate Judge 

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UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Joseph C. Spero

Case 3:17-cr-00044-VC Document 18 Filed 03/18/16 Page 2 of 2