STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

GARLAND E. BURRELL, Jr., Senior District Judge.

STIPULATION

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

1. By previous order, this matter was set for status on July 10, 2015.

2. By this stipulation, defendants now move to continue the status conference until August 21, 2015 and to exclude time between July 10, 2015 and August 21, 2015 under Local Code T4. The United States does not oppose this request.

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

a) The United States has represented that the discovery associated with this case includes investigative reports and wiretap applications in electronic form constituting approximately 4000 pages of documents. The United States also represents that the discovery includes approximately 20 CDs of audio recordings, including intercepted communications, and transcripts and line reports. All of this discovery has been produced directly to counsel.

b) Counsel for the defendant desires additional time to consult with his client, to conduct investigation and research related to the charges, to review discovery for this matter, to discuss potential resolutions with his client, and to otherwise prepare for trial.

c) Counsel for defendant has also received a plea agreement. Counsel for the defendant needs additional time to review the discovery with respect to the factual basis and to conduct research with respect to the implications for trial presented in the plea agreements.

d) Counsel for the defendant further has represented that he has been and remains engaged in a state court trial.

e) Counsel for the defendant believes that the 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.

f) The United States does not object to the continuance.

g) 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.

h) 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 July 10, 2015 through August 21, 2015, 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 FOUND AND ORDERED.