Filed: Jul. 24, 2019
Latest Update: Jul. 24, 2019
Summary: AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on July 25, 2019. 2. By this stipulation, defendant now moves to continue the status conference until September 12, 2019, and to exclud
Summary: AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on July 25, 2019. 2. By this stipulation, defendant now moves to continue the status conference until September 12, 2019, and to exclude..
More
AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER
MORRISON C. ENGLAND, JR., District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on July 25, 2019.
2. By this stipulation, defendant now moves to continue the status conference until September 12, 2019, and to exclude time between July 25, 2019, and September 12, 2019, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the discovery associated with this case includes multiple reports, spreadsheets, and videos. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b) The parties plan to meet to discuss the evidence in the next few weeks. Specifically, the government will explain to defense counsel what the various data points in the spreadsheets mean.
c) Counsel for defendant desires additional time review the evidence underlying the summary charts and spreadsheets, conduct independent investigation, and otherwise prepare for trial.
d) Counsel for defendant believes that failure to grant the above-requested continuance would deny him/her 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 July 25, 2019 to September 12, 2019, 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.
Dated: July 23, 2019 MCGREGOR W. SCOTT
United States Attorney
/s/ CAMERON L. DESMOND
CAMERON L. DESMOND
Assistant United States Attorney
Dated: July 23, 2019 /s/ DINA SANTOS
DINA SANTOS
Counsel for Defendant
CELESTE PANG
ORDER
IT IS SO ORDERED.
