STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

WILLIAM B. SHUBB, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel of record, and defendants FRANCISCO FELIX, ALEJANDRO MARTINEZ, AUGUSTIN RAMIREZ, GERARDO BARRAZA, MARTIN LOPEZ, RAUL RANGEL, ALFONSO MAGANA, RAFAEL ALCAUTER, MARTIN RUBIO, and RAMON DIAZ, by and through their respective counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on June 30, 2014, at 9:30 a.m.

2. By this stipulation, defendants now move to continue the status conference to August 25, 2014, at 9:30 a.m., and to exclude time between June 30, 2014, and August 25, 2014, under Local Codes T2 and T4. Plaintiff does not oppose this request.

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

a. This case involves a year long, multi-agency, investigation in which telephone calls were intercepted pursuant to Title III.

b. The government has produced discovery to the defense in this case which consists of approximately 19,194 pages of scanned documents and approximately 14 CD/DVD's with videos, recorded body wires, and recorded conversations.

c. Respective counsel for each defendant desires additional time to review the document and multi-media discovery, consult with their client regarding the discovery, conduct investigation, and to discuss potential resolution with their client and the government.

d. Counsel for each defendant believes that failure to grant the above-requested continuance would deny defendants the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

e. The government does not object to the continuance.

f. 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 defendants in a trial within the original date prescribed by the Speedy Trial Act.

g. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of June 30, 2014, to August 25, 2014, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(ii), B(iv), [Local Codes T2 and T4] because it results from a continuance granted by the Court at defendants' 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.

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.

ORDER

IT IS SO FOUND AND ORDERED.