STIPULATION AND [PROPOSED] ORDER

GARLAND E. BURRELL, Jr., District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendants Mohammad Khan, Harjit Johal and Jasvir Kaur, by and through their counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for a trial confirmation hearing on October 23, 2015. Trial in this matter is currently set to commence November 10, 2015.

2. By this stipulation, defendants now move to vacate the trial confirmation hearing, vacate the trial date and set a status hearing for January 8, 2016. The defendants seek to exclude time under Local Code T4. Plaintiff does not oppose this request.

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

a. On or about October 1, 2015 the grand jury returned a superseding indictment. The superseding indictment adds Jasvir Kaur as a defendant in this case. Ms. Kaur was arraigned on October 6, 2015.

b. The government has forwarded discovery to counsel for Ms. Kaur. Defense counsel has yet to receive said discovery. Upon receipt of the discovery, defense counsel for Ms. Kaur will require time to review the discovery, meet with Ms. Kaur and conduct an appropriate investigation.

c. An exclusion of time is appropriate as to Misters Khan and Johal in order to provide for continuity of counsel.

d. The government does not object to the continuance.

e. 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 defendants in a trial within the original date prescribed by the Speedy Trial Act.

f. 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 October 23, 2015 to January 8, 2016, 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 each 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 defendants in a speedy trial.

g. This case involves multiple witnesses, multiple defendants; both defendants and the witnesses require interpreters.

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.

ORDER

IT IS SO FOUND AND ORDERED.