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

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

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant Jodene Watt, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on August 15, 2014.

2. By this stipulation, defendant now moves to continue the status conference until October 17, 2014 and to exclude time between August 15, 2014 and October 17, 2014 under Local Code T4. The United States does not oppose this request.

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

a) The United States has represented that the discovery associated with this case includes investigative reports and wiretap applications in electronic form constituting approximately 4000 pages of documents. The United States also represents that the discovery includes approximately 20 CDs of audio recordings, including intercepted communications, and transcripts and line reports. All Stipulation and Proposed Order re: Continuance of 1 Status Hearing and Exclusion of Time of this discovery has been produced directly to counsel.

b) Counsel for defendant desires additional time to consult with his client, to conduct investigation and research related to the charges, to review discovery for this matter, to discuss potential resolutions with his client, and to otherwise prepare for trial.

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

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 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 August 15, 2014 to October 17, 2014, 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.

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.