Filed: Apr. 15, 2014
Latest Update: Apr. 15, 2014
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER MORRISON C. ENGLAND, Jr., District Judge. The United States of America through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with counsel for defendant Manuel Keith, Jan David Karowsky, Esq. hereby stipulate to the following: 1. By previous order, this matter was set for status conference on April 17, 2014. 2. By this stipulation, both the government and Manuel Keith mov
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER MORRISON C. ENGLAND, Jr., District Judge. The United States of America through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with counsel for defendant Manuel Keith, Jan David Karowsky, Esq. hereby stipulate to the following: 1. By previous order, this matter was set for status conference on April 17, 2014. 2. By this stipulation, both the government and Manuel Keith move..
More
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
MORRISON C. ENGLAND, Jr., District Judge.
The United States of America through its undersigned counsel, Jason Hitt, Assistant United States Attorney, together with counsel for defendant Manuel Keith, Jan David Karowsky, Esq. hereby stipulate to the following:
1. By previous order, this matter was set for status conference on April 17, 2014.
2. By this stipulation, both the government and Manuel Keith move to continue the status conference until June 26, 2014 and to exclude time between April 17, 2014 and June 26, 2014 under the Local Code T-2 and T-4.
3. The parties agree and stipulate and request the Court find the following:
a. This case was the product of a lengthy investigation in which wiretaps were utilized on multiple telephones. The government has produced discovery which to date includes 1,952 pages containing wiretap applications, periodic reports, and investigative materials. Additionally, the government has provided defense counsel with voluminous wiretap conversations. Given this large volume of discovery, counsel for Mr. Keith needs additional time to review the discovery and consult with him. Additionally, a continuance now will provide the government and defense counsel the needed time to negotiate and hopefully, finalize a plea agreement. It is expected the government will be able to provide a plea agreement to Mr. Keith and a guilty plea is hoped to be entered at the next status conference.
b. The Government also requests the continuance.
c. Based on the above-stated findings, the ends of justice served by granting the requested continuance outweigh the best interests of the public and the defendant in a speedy trial within the original date prescribed by the Speedy Trial Act.
d. For the purpose of computing time under the Speedy Trial Act, 18 United States Code Section 3161(h)(7)(A) within which trial must commence, the time period of April 17, 2014 through June 26, 2014 inclusive, is deemed excludable pursuant to 18 United States Code Section 3161(h)(7)(A)) and (B)(ii) and (iv), corresponding to Local Code T-2 and T-4 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.
DATED: April 15, 2014 BENJAMIN WAGNER
United States Attorney
/s/Jason Hitt
by
Jason Hitt
Assistant U.S. Attorney
by Jan David Karowsky
w/Mr. Hitt's consent
ORDER
IT IS SO FOUND AND ORDERED.
