STIPULATION AND PROPOSED ORDER TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT AS TO ALL DEFENDANTS

JON S. TIGAR, District Judge.

The parties hereby STIPULATE and AGREE as follows:

1. On April 14, 2017, a federal grand jury in the Northern District of California returned a five-count Indictment alleging that Defendants Kenneth Taylor, Sharon Ringgenberg, and Craig Scott conspired to and did commit wire fraud with respect to a business providing fraudulent standby letters of credit and proof of funds statements, in violation of 18 U.S.C. §§ 1343 and 1349, and that Kenneth Taylor signed and filed false 2009 and 2010 federal income tax returns in which he failed to report income from the fraud scheme, in violation of 26 U.S.C. § 7206(1).

2. On May 22, 2017, the Court issued a Protective Order regarding the discovery materials that the government plans to serve on Defendants. See Doc. No. 17.

3. On May 25, 2017, the government served initial discovery on all defendants. The government estimates that this production contains in excess of 70,000 pages of documents.

4. On May 26, 2017, Kenneth Taylor and Craig Scott, represented by their respective counsel, and the government, represented by Assistant U.S. Attorney Colin Sampson, appeared for an initial status hearing before United States District Judge Jon S. Tigar. The matter was continued to July 21, 2017, in order for counsel to review recently-produced discovery.

5. On July 17, 2017, the United States made an additional production of several thousand additional pages of documents to defendants.

6. On July 21, 2017, all defendants appeared at a status conference in this matter. A further status conference was scheduled for September 29, 2017, for counsel to continue reviewing discovery and for the government to produce electronic discovery materials that have not yet finished processing.

7. During late September, 2017, the United States made productions to defendants of approximately 100,000 pages of discovery as well as audio recordings.

8. On September 29, 2017, all defendants appeared at a status conference in this matter. A further status conference was scheduled for January 12, 2018, at which the parties expect to set a briefing and trial schedule.

Accordingly, the United States and Defendants Kenneth Taylor, Sharon Ringgenberg, and Craig Scott, hereby STIPULATE AND AGREE that time under the Speedy Trial Act be excluded from September 29, 2017, through January 12, 2018, pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (b)(iv) to allow for effective preparation of counsel, taking into account the exercise of due diligence.

ORDER

Pursuant to the Stipulation of the United States of America and Defendants Kenneth Taylor, Sharon Ringgenberg, and Craig Scott, and for good cause shown therein, time under the Speedy Trial Act is excluded from September 29, 2017, through January 12, 2018, pursuant 18 U.S.C. §§ 3161(h)(7)(A) and (b)(iv) because the ends of justice outweigh the interests of the public and the Defendants in a speedy trial, and to allow for effective preparation of counsel, taking into account the exercise of due diligence, in order for the Defendants to review discovery served upon them by the United States.

IT IS SO ORDERED.