Filed: Aug. 20, 2018
Latest Update: Aug. 20, 2018
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION Defendant, Sequioya Harris, by and through her counsel, Toni White, defendant John A. Owens, Jr., by and through his counsel, Kresta Daly, defendant Dionne M. Thomas, by and through her counsel, Robert Wilson, defendant Jose E. Rodriquez, Jr., by and through his counsel, Olaf Hedberg, and the Government, by and through its counsel, Christopher S. Hales, hereby stipulate
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION Defendant, Sequioya Harris, by and through her counsel, Toni White, defendant John A. Owens, Jr., by and through his counsel, Kresta Daly, defendant Dionne M. Thomas, by and through her counsel, Robert Wilson, defendant Jose E. Rodriquez, Jr., by and through his counsel, Olaf Hedberg, and the Government, by and through its counsel, Christopher S. Hales, hereby stipulate a..
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STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER
JOHN A. MENDEZ, District Judge.
STIPULATION
Defendant, Sequioya Harris, by and through her counsel, Toni White, defendant John A. Owens, Jr., by and through his counsel, Kresta Daly, defendant Dionne M. Thomas, by and through her counsel, Robert Wilson, defendant Jose E. Rodriquez, Jr., by and through his counsel, Olaf Hedberg, and the Government, by and through its counsel, Christopher S. Hales, hereby stipulate as follows:
1. By previous order, this matter was set for status on August 21, 2018
2. By this stipulation, defendants now move to continue the status conference until October 23, 2018, and to exclude time between August 21, 2018, and October 23, 2018, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has provided additional discovery in this matter that counsel for the defendants are still reviewing. The discovery associated with this case is at 32,501 bates stamped pages consisting of voluminous tax and bank records as well as audio and video discovery. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b) Counsel for the defendants desire this time to continue to review the discovery and analyze the same, to consult with their clients, to review the current charges, to conduct investigation and research related to the charges, to review the discovery, and to discuss potential resolutions with their clients and otherwise prepare for trial.
c) Counsel for the defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account 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 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 21, 2018 to October 23, 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.
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.
