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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: October 25, 2016

Time: 9:30 a.m.

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

October 25, 2016. The parties request that this matter be continued to December 8, 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 October 25, 2016 to 

the newly proposed hearing date to accommodate this request, and defense counsel is continuing to 

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

result, the parties request that the Court exclude time between October 25, 2016 and December 8, 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 that the ends of justice served by granting the continuance outweigh the best interests of 

/ / /

/ / /

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STIPULATION AND [Proposed] ORDER 

CONTINUING HEARING AND EXCLUDING TIME

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the public and the defendant in a speedy trial. 

Dated: October 24, 2016 Brian J. Stretch

United States Attorney 

/S/ 

William Frentzen

Assistant United States Attorney

Dated: October 24, 2016 /S/ 

Mark R. Vermeulen

Attorney for Defendant 

WEN BING LEI

ORDER

IT IS HEREBY ORDERED that this matter is continued to December 8, 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 December 8, 2016.

IT IS FURTHER ORDERED that time between October 25, 2016 and December 8, 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: October ___, 2016 _____________________________

Elizabeth D. Laporte

United States Magistrate Judge

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Case 3:17-cr-00044-VC Document 26 Filed 10/24/16 Page 2 of 2