STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER

MORRISON C. ENGLAND, Jr., Chief District Judge.

STIPULATION

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

1. By previous order, this matter was set for status on June 19, 2014.

2. By this stipulation, defendants now move to continue the status conference until August 21, 2014, and that date is available with the Court

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

a. The government has provided over 6,000 pages of discovery, including investigative reports and related documents in electronic form, over 3 hours of audio taped interviews with Sacramento Metropolitan Fire investigators and local law enforcement and other witnesses and photographs. Alexander Sakhaniskiy has recently obtained new counsel. Counsel will need to review reports and engage in investigation.

b. Counsel for Larissa Sakhaniskiy has hired a fire investigation expert to review evidence in this matter. Counsel continues to review discovery and actively investigate this matter. Counsel desire additional time to consult with their clients, to continue investigation and research related to the charges, to review and copy discovery for this matter, to discuss potential resolutions with clients, to prepare pretrial motions, and to otherwise prepare for trial.

c. Counsel for defendants believe that failure to grant the above-requested continuance would deny defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

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 defendant 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 June 19, 2014 to August 21, 2014 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.

ORDER

IT IS SO ORDERED.