STIPULATION AND ORDER FOR CONTINUANCE OF STATUS CONFERENCE

JOHN A. MENDEZ, District Judge.

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Matthew Segal, Assistant United States Attorney, attorney for Plaintiff, Kresta N. Daly, attorney for defendant John Michael Herron, and Candice L. Fields, attorney for defendant Robert Joseph Maher, that:

1. By previous order, this matter was set for a status conference on January 15, 2019, at 9:15 a.m., before Judge John A. Mendez.

2. By this stipulation, defendants now move to continue the status conference until March 26, 2019, at 9:15a.m. before Judge John A. Mendez, and to exclude time between January 25, 2028, and March 26, 2019, inclusive, under Local Code T4 (to allow defense counsel time to prepare).

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

a. On or around December 17, 2018, the government produced more than 14,000 pages of discovery associated with this case directly to counsel and/or made available for inspection and copying.

b. Counsel for defendants desire additional time to review the discovery only recently produced in this matter, consult with their clients, review the current charges, conduct investigation and research related to the charges, and to discuss potential resolutions 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, 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 January 15, 2019, to March 26, 2019, 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 defendants 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.

ORDER

IT IS HEREBY ORDERED that the status conference hearing set for January 15, 2019, at 9:15 a.m., be vacated and continued to March 26, 2019, at 9:15 a.m.

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 from the date of this order through March 26, 2019, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161 (h)(7)(A), (B)(iv) and Local Code T4, because it results from a continuance granted by the Court at both parties' 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.