UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA, CRIMINAL ACTION

NO. 09-CR-20192

 Plaintiff, 

HON. JULIAN ABELE COOK

D-1 GHAZI MANNI, et al., 

 Defendants.

_____________________________/

STIPULATION FOR CONTINUANCE OF TRIAL DATE

AND FINDING OF EXCLUDABLE DELAY

In accordance with decisions made by the Court and the parties at the status

conference held on February 11, 2013, the parties through their respective counsel

stipulate and agree that a pretrial conference will be held at 1:00 p.m. on June 18,

2013, and that trial will commence at 8:30 a.m. on July 2, 2013.

Pursuant to 18 U.S.C. § 3161(h)(7)(A), the parties stipulate that the extended

time period from February 11, 2013 until the trial begins on July 2, 2013, shall

constitute excludable delay and that the ends of justice served by this delay

outweigh the best interests of the defendants and the public in a speedy trial. The

parties agree that the delay until trial is necessary for the following reasons: (1) as

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a result of factors previously explained to the Court in chambers, trial preparation

has been hampered on both sides; (2) a trial conflict has arisen involving an

attorney for one of the defendants; (3) the discovery in the case is voluminous and

the defendants require additional time to complete their review of the discovery

materials in order to: (a) consider, prepare, and file pretrial motions; (b) evaluate

their need for expert defense witnesses; (c) consider and conduct plea negotiations,

and; (d) to adequately prepare for a lengthy trial.

IT IS SO STIPULATED.

 

BARBARA L. McQUADE 

United States Attorney

s/David E. Morris s/Saima Mohsin 

DAVID E. MORRIS (P61451) SAIMA MOHSIN (P73990)

Assistant U.S. Attorney Assistant U.S. Attorney

211 W. Fort Street, Suite 2001 211 W. Fort Street, Suite 2001

Detroit, Michigan 48226 Detroit, Michigan 48226

Dave.Morris@usdoj.gov Saima.Mohsin@usdoj.gov

Telephone: (313) 226-9646 Telephone: (313) 226-9163

s/Neil H. Fink with consent

NEIL H. FINK (P13430)

Attorney for Ghazi Manni

185 Oakland Avenue, Suite 250

Birmingham, MI 48009

Telephone: (248) 258-3181

Dadcoach23@aol.com

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s/Ray E. Richards II with consent s/Martin E. Crandall with consent

RAY E. RICHARDS II (P56972) MARTIN E. CRANDALL (P26824)

Attorney for Keith Triplett Attorney for Anton Currie

29488 Woodward Avenue, Suite 444 Clark Hill PC

Royal Oak, MI 48073 500 Woodward Avenue, Suite 3500

Telephone: (248) 962-0700 Detroit, MI 48226

Rayrichardsesq@gmail.com Telephone: (313) 965-8413

mcrandall@clarkhill.com

s/Stevin J. Groth with consent

STEVIN J. GROTH

Attorney for Kashif Payne 

416 N. Erie Street, Suite 100 

Toledo, OH 43604

Telephone: (419) 930-3030

stevingroth@hotmail.com

Dated: February 15, 2013.

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UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF MICHIGAN

SOUTHERN DIVISION

UNITED STATES OF AMERICA, CRIMINAL ACTION

NO. 09-CR-20192

 Plaintiff, 

HON. JULIAN ABELE COOK

D-1 GHAZI MANNI, et al., 

 Defendants.

_____________________________/

ORDER FOR CONTINUANCE OF TRIAL DATE

AND FINDING OF EXCLUDABLE DELAY

Upon this Court's consideration of the parties' stipulation for a continuance

and the Court being apprised of the circumstances, IT IS ORDERED that a pretrial

conference will be held at 1:00 p.m. on June 18, 2013, and that trial will commence

at 8:30 a.m. on July 2, 2013.

IT IS FURTHER ORDERED that the time period between the pretrial

conference held on February 11, 2013, and the trial to be held on July 2, 2013,

shall be deemed excludable delay under the provisions of the Speedy Trial Act, 18

U.S.C. § 3161, because considering the factors listed in section 3161(h)(7)(B) and

the reasons given by the parties this Court finds that the ends of justice served by

this delay outweigh the best interests of the defendants and the public in a speedy

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trial.

IT IS SO ORDERED.

Date: March 1, 2013 s/Julian Abele Cook, Jr. 

JULIAN ABELE COOK, JR.

United States District Judge

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