Filed: May 16, 2019
Latest Update: May 16, 2019
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER GARLAND E. BURRELL, JR. , District Judge . STIPULATION 1. By previous order, this matter was set for status on May 17, 2019. 2. By this stipulation, defendants now move to continue the status conference until July 26, 2019, and to exclude time between May 17, 2019, and July 26, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a)
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER GARLAND E. BURRELL, JR. , District Judge . STIPULATION 1. By previous order, this matter was set for status on May 17, 2019. 2. By this stipulation, defendants now move to continue the status conference until July 26, 2019, and to exclude time between May 17, 2019, and July 26, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a) ..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER
GARLAND E. BURRELL, JR., District Judge.
STIPULATION
1. By previous order, this matter was set for status on May 17, 2019.
2. By this stipulation, defendants now move to continue the status conference until July 26, 2019, and to exclude time between May 17, 2019, and July 26, 2019, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) On April 3, 2019, the government produced discovery associated with this case that consisted of over 3000 pages of documents, including investigative reports, bank records, photographs, and other types of records.
b) On April 17, 2019, the government produced over 5000 pages of additional discovery, including Cellebrite reports.
c) Counsel for defendants require time to review the recently produced discovery and discuss the case with their clients.
d) 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.
e) The government does not object to the continuance.
f) 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.
g) 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 May 17, 2019 to July 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 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.
Dated: May 15, 2019. McGREGOR W. SCOTT
United States Attorney
/s/ MIRIAM R. HINMAN
MIRIAM R. HINMAN
Assistant United States Attorney
Dated: May 15, 2019. /s/ HANNAH LABAREE
HANNAH LABAREE
Counsel for Defendant
MARIE ANTOINETTE ALCANTER
Dated: May 15, 2019. /s/ KYLE KNAPP
KYLE KNAPP
Counsel for Defendant
ROSE MARIE SEGALE
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
