STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE AND FOR EXCLUSION OF TIME

HAYWOOD S. GILLIAM, Jr., District Judge.

The parties hereby stipulate and ask the Court to find and order as follows:

1. The parties appeared in this case on July 31, 2017, for a status hearing. The Court continued this case for one month to August 28, 201, in order to allow for the production of extensive electronic discovery — more than 100 GB of data.

2. The Government has been working diligently to process data in order to provide TIFF images and load files in accordance with the Guidelines on Electronic Discovery in Criminal Cases. The effort has taken more time to achieve than the parties initially anticipated, and full discovery has yet to be produced.

3. Accordingly, the parties respectfully request that the Court enter an order continuing the current status conference until September 25, 2017, to allow discovery production to be completed.

4. Counsel for defendant requests this additional time for effective preparation of counsel, taking into account the exercise of due diligence. The government does not object to the continuance. The parties stipulate, and would ask the Court to so find, that 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. See 18 U.S.C. § 3161(h)(7)(A).

5. The parties agree that good cause exists for the extension of time and that the extension would not adversely affect the public interest in the prompt disposition of criminal cases. Therefore, the parties request that the time between August 28, 2017 (current date for the status conference), and September 25, 2017 (new date of the status conference), be excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv).

SO STIPULATED:

GOOD CAUSE HAVING BEEN SHOWN, IT SO ORDERED: