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

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

STIPULATION

1. By previous order, this matter was set for status on January 20, 2017.

2. By this stipulation, defendants now move to continue the status conference until April 7, 2017, and to exclude time between January 20, 2017, and April 7, 2017, under Local Code T4.

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

a) The government has represented that the discovery associated with this case includes 800 pages of interview reports and documents obtained through the investigation and 90 discs containing audio and video files. All of this discovery has been produced directly to counsel.

b) Counsel for defendant Mangal Gill substituted in August 2016 and additional counsel joined in January 2017, and each are still reviewing discovery.

c) Counsel for all defendants also desire additional time to investigate the case, including to conduct legal research as to any potential defenses, and to discuss the matter with their clients.

d) Further, counsel for defendant Robert Turchin will be in trial on various dates until April 2017.

e) Counsel for defendants believe that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

f) The government does not object to the continuance.

g) 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.

h) 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 January 20, 2017 to April 7, 2017, 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 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.

FINDINGS AND ORDER

IT IS SO FOUND AND ORDERED.