Filed: Feb. 15, 2018
Latest Update: Feb. 15, 2018
Summary: STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR FEBRUARY 16, 2018 TO May 4, 2018 GARLAND E. BURRELL, JR. , Senior District Judge . IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Jared Dolan, Assistant United States Attorney, that the status conference currently set for February 16, 2018 should be contin
Summary: STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR FEBRUARY 16, 2018 TO May 4, 2018 GARLAND E. BURRELL, JR. , Senior District Judge . IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Jared Dolan, Assistant United States Attorney, that the status conference currently set for February 16, 2018 should be continu..
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STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR FEBRUARY 16, 2018 TO May 4, 2018
GARLAND E. BURRELL, JR., Senior District Judge.
IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Jared Dolan, Assistant United States Attorney, that the status conference currently set for February 16, 2018 should be continued until May 4, 2018, and to exclude time between February 16, 2018 and May 4, 2018, under Local Code T4.
The parties agree and stipulate, and request that the Court find the following:
1. An Order substituting attorney Hayes Gable III in place of attorney Bruce Locke as counsel for Kioñil Dogan was signed by the Court on February 12, 2018. The government has provided discovery associated with this case, which is voluminous — i.e. approximately 14,000 pages, plus media materials, to defense counsel.
2. Counsel for defendant Dogan thus requires adequate time to review discovery and consult with client and conduct any necessary investigation and research related to the charges, and to otherwise prepare for trial.
3. Given the volume of discovery, counsel for defendants Harris and Bailey also require additional time to review the discovery in this matter, to consult with client and conduct any necessary investigation and research related to the charges, and to otherwise prepare for trial.
4. Counsel for the government is unopposed.
5. Counsel for defendants believes that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
6. The government and counsel for defendants Dogan and Bailey join in the request for the continuance.
7. 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.
8. 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 February 16, 2018, to May 4, 2018, inclusive, is deemed excludable pursuant to 18 U.S.C. section 3161(h)(7)(A), B(iv)[Local Code T4] because it results from a continuance granted by the Court at counsel's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the interest of the public and the defendant in a speedy trial.
9. 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.
