STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER

RICHARD SEEBORG, District Judge.

This case was originally assigned to the Honorable Charles R. Breyer. On August 31, 2017, this Court related this case to United States v. Husain, CR 14-149 RS, and ordered it reassigned. The parties request that the case be set for a status conference before this Court on November 7, 2017, at 2:30 p.m.

The parties further request that the time between August 30, 2017, and November 7, 2017, be excluded under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B). This is a securities fraud case with substantial discovery. Defense counsel was recently retained by defendant. The government has produced approximately 1 million documents to the defense, which the defense has only begun to review. Excluding time until November 7, 2017, will allow for the effective preparation of counsel, taking into account the nature of the prosecution and the particular complexity of this case, and the ends of justice served by this delay outweigh the defendant's and the public's interest in a speedy trial. See 18 U.S.C. § 3161(h)(7)(B)(ii), (iv).

IT IS SO STIPULATED.

[PROPOSED] ORDER

The Court finds that the exclusion of the period from August 30, 2017, and November 7, 2017, from the time limits applicable under 18 U.S.C. § 3161, is warranted; that the ends of justice served by the continuance outweigh the interests of the public and the defendants in the prompt disposition of this criminal case; and that the failure to grant the requested exclusion of time would deny counsel for defendant the reasonable time necessary for effective preparation and of counsel, taking into account the particular complexity of the case and the exercise of due diligence, and would result in a miscarriage of justice. See 18 U.S.C. § 3161(h)(7)(B)(ii), (iv).

IT IS SO ORDERED.