STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME FROM OTHERWISE APPLICABLE SPEEDY TRIAL ACT CALCULATION

RICHARD SEEBORG, District Judge.

STIPULATION

IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that:

1. The parties appeared before the Court on November 10, 2015, at 2:30 p.m. for a status hearing. Mr. Zhou was represented by Richard Tamor. Special Assistant United States Attorneys Daniel Talbert and Katherine M. Lloyd-Lovett appeared for the Government. The parties requested a continuance of the matter, with time excluded for effective preparation of counsel to December 15, 2015.

2. On November 11, 2015, the Court signed an order excluding time until December 15, 2015.

3. Undersigned counsel for Mr. Zhou has made significant progress in reviewing the discovery produced by the government with Mr. Zhou. However, because Mr. Zhou is a native Contonese speaker, we have not completed this process. In addition, undersigned counsel has also made significant progress in investigating this matter, but again, because virtually all of the relevant witnesses in this matter are native Cantonese speakers, defense investigation is still not complete.

3. Accordingly, with the Court's permission, the parties hereby agree and stipulate to continue the status conference currently scheduled for December 15, 2015, at 2:30 p.m. to January 12, 2015 at 2:30 p.m. The parties also respectfully submit and agree that the period from December 15, 2015 through and including January 12, 2016 should be excluded from the otherwise applicable Speedy Trial Act computation because the continuance is necessary for effective preparation of counsel, taking into account the exercise of due diligence.

4. The parties concur that granting the exclusion would allow the reasonable time necessary for effective preparation of counsel and continuity of counsel. 18 U.S.C. §3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such an exclusion of time for the purposes of effective preparation of counsel outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

IT IS SO STIPULATED.

[PROPOSED] ORDER

Based upon the above-described Stipulation, THE COURT FINDS THAT the ends of justice served by granting a continuance from December 15, 2015 through and including January 12, 2016 outweigh the best interest of the public and the defendant in a speedy trial, and that failure to grant such a continuance would unreasonably deny the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

Accordingly, THE COURT ORDERS THAT:

1. The parties shall appear before the Court on January 12, 2016 at 2:30 p.m. for further status conference.

2. The period from December 15, 2015 through and including January 12, 2016 is excluded from the otherwise applicable Speedy Trial Act computation, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(iv).

IT IS SO ORDERED.