STIPUATION AND ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT

GARLAND E. BURRELL, JR., Senior District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendants CHI MENG YANG and GAOSHENG LAITINEN, by and through their counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on June 1, 2018.

2. By this stipulation, defendants now move to continue the status conference until June 29, 2018, and to exclude time between June 1, 2018 and June 29, 2018 under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has provided approximately 40 discs of discovery. Further discovery is expected to be produced.

b. Counsel for defendants' desire additional time to complete the review of discovery, to conduct defense investigation, and to discuss potential resolution with their clients.

c. Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, considering the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.

f. For computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time-period of June 1, 2018 and June 29, 2018, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h) (7) (A), B (iv) [Local Code T4] because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial. Time is also excluded for continuity of counsel under 18 USC 3161(h)(7)(B)(IV) and 18 USC 3161(h)(6), Local Code R (unsevered co-defendanrt, Ms. Laitinen) as to whom the time for trial has not run and no motion for severance had been granted."

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

IT IS SO STIPULATED.

IT IS SO ORDERED.