STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE AND EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] ORDER STIPULATION

GARLAND E. BURRELL, Jr., District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status conference on January 22, 2016.

2. By this stipulation, defendant now moves to continue the status conference to March 25, 2016, and to exclude time between January 22, 2016 and March 25, 2016, 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 approximately seventeen boxes of discovery containing bank records and other corporate records produced by third-party custodians. All of this discovery has been either produced directly to counsel or made available for inspection and copying. The defendant's representatives spent multiple days at the FBI office in Sacramento having the documents and CD's copied.

b. Counsel for the government has indicated to Defendant's counsel that they will be providing additional discovery based upon the further investigation in this case.

c. Counsel for defendant desires additional time to review the discovery and discuss the case and other matters with the government.

d. Counsel for defendant believes that failure to grant the above-requested continuance would deny him 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 January 22, 2016 to March 25, 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 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.

IT IS SO ORDERED.