STIPULATED REQUEST TO CONTINUE HEARING 

CR 17-0091 JD

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 

Wolf, Pennella & Stevens, LLP 

Adam Pennella, State Bar No. 246260 

717 Washington Street 

Oakland, CA 94607 

Phone (510) 451-4600 

Fax (510) 451-3002 

adam@wps-law.com 

Counsel for Defendant 

PEIWEN ZHOU 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

OAKLAND DIVISION 

UNITED STATES OF AMERICA, 

Plaintiff, 

v. 

PEIWEN ZHOU, 

AK SCIENTIFIC, INC, 

Defendants. 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

) 

No. CR 17-0091 JD 

STIPULATION AND [PROPOSED] ORDER TO 

CONTINUE STATUS HEARING 

 The above-captioned matter is currently set for a status conference on June 28, 2017. Based 

upon the information set forth below, the parties respectfully request that the Court continue this matter 

to September 13, 2017, and that the Court exclude time under the Speedy Trial Act, 18 U.S.C. § 3161, 

for effective preparation and continuity of counsel, as well as to allow the parties to confer regarding 

potential case resolution. 

 On March 22, 2017, the parties appeared before this Court for the initial District Court 

appearance. By that time, the government had produced a significant amount of discovery, including 

thousands of pages of reports and related documents, as well as millions of emails. Undersigned defense 

counsel has been diligently reviewing the discovery. 

 The parties have already begun discussions regarding resolution of the case. Moreover, and as 

part of those discussions, the parties are arranging for a site visit at AK Scientific, Inc. with the 

government (and investigators) related to Defendants’ ongoing remediation of various business and 

Case 4:17-cr-00091-JD Document 10 Filed 06/26/17 Page 1 of 2
STIPULATED REQUEST TO CONTINUE HEARING 

CR 17-0091 JD

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 

shipping practices. That visit has not yet been scheduled but that parties anticipate that it will happen 

sometime in the middle of the summer. The proposed date provides the parties sufficient time to 

complete discovery, conduct the site visit, and accommodate counsels’ vacation and work obligations. 

 As such, the parties request that the status appearance be continued for the reasons set forth 

above. 

 It is further stipulated that time be excluded through September 13, 2017, for effective 

preparation and continuity of counsel. 

SO STIPULATED: 

Dated: June 23, 2017 BRIAN STRETCH 

 UNITED STATES ATTORNEY 

 _____________/s/_____________ 

 Waqar Hasib 

 Assistant United States Attorney 

Dated: June 23, 2017 _____________/s/_____________ 

 Paul Wolf 

 Counsel for Peiwen Zhou 

Dated: June 23, 2017 _____________/s/_____________ 

 Charles Woodson 

 Counsel for AK Scientific, Inc. 

SO ORDERED: 

Dated: __________________________ 

 Honorable James Donato 

 United States District Court Judge 

Case 4:17-cr-00091-JD Document 10 Filed 06/26/17 Page 2 of 2

June 27, 2017

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

APPROVED

Judge James Donato J