STIPULATION REGARDING TRIAL DATES, MOTION SCHEDULE, AND EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

GARLAND E. BURRELL, JR., Senior District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant Joshua I. Ramson, by and through his counsel of record, Kresta Daly, hereby stipulate as follows:

1. By previous order, this matter was set for status on January 26, 2018.

2. By this stipulation, the parties now jointly move to (1) vacate the January 26, 2018 status conference, (2) set a trial date of December 4, 2018, (3) set a pretrial motions deadline of August 17, 2018, (4) set a trial confirmation hearing on October 12, 2018, and (5) exclude time between January 26, 2018, and December 4, 2018, under Local Code T4.

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

a) The discovery associated with this case includes investigative reports and related Documents, police video footage, and other relevant documents. All of this discovery has been produced directly to counsel for the defendant.

c) Counsel for the defendant desires additional time to investigate the case, discuss potential pre-trial motions with her client, conduct additional legal and factual research, and review and analyze the discovery in this matter. Given the nature of the charges, and the further investigation she wishes to do, defense counsel believes that an exclusion of time through the first day of trial is justified by her need to prepare adequately for trial.

d) Counsel for the defendant believes that failure to grant the above-requested exclusion of time under the Speedy Trial Act would deny the defendant and his counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

e) The government joins in the request.

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 January 26, 2018 to December 4, 2018, 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 the 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.

4. In order to conserve judicial resources, the parties further stipulate that setting a motions schedule for any pretrial motions (other than motions in limine) is appropriate at this time. Accordingly, the parties request that the Court adopt the following pretrial motions schedule: all pretrial motions shall be due on or before August 17, 2018; any opposition by the nonmoving party shall be due on or before August 31, 2018; and the moving party's reply shall be due on or before September 7, 2018.

5. Finally, the parties request that this Court set a trial confirmation hearing for October 12, 2018.

6. 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. For example, the filing of pretrial motions may independently exclude time in this case prior to their prompt disposition, per Local Code E.

IT IS SO STIPULATED.

FINDINGS AND ORDER

IT IS SO FOUND AND ORDERED.