Filed: Jul. 16, 2015
Latest Update: Jul. 16, 2015
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER SHEILA K. OBERTO , Magistrate Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant BAHAR GHARIB-DANESH, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order in the United States District Court for the Central District of California, this matter was set for defendant GHARIB-DANESH's initial appearance in t
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER SHEILA K. OBERTO , Magistrate Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant BAHAR GHARIB-DANESH, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order in the United States District Court for the Central District of California, this matter was set for defendant GHARIB-DANESH's initial appearance in th..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
SHEILA K. OBERTO, Magistrate Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant BAHAR GHARIB-DANESH, by and through defendant's counsel of record, hereby stipulate as follows:
1. By previous order in the United States District Court for the Central District of California, this matter was set for defendant GHARIB-DANESH's initial appearance in this district and status conference on July 24, 2015.
2. A status conference for the two co-defendants in this case has been set for August 17, 2015, at 1:00 p.m. before the Hon. Sheila K. Oberto. The parties wish to change the date for defendant GHARIB-DANESH's initial appearance in this district to the same date that the co-defendants have a status conference.
3. By this stipulation, defendant now moves to continue the status conference until August 17, 2015, at 1:00 p.m., and to exclude time between July 24, 2015, and August 17, 2015, under 18 U.S.C. § 3161(h)(7)(A), B(iv).
4. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the initial discovery associated with this case includes approximately 33,000 pages of material. This discovery will be produced on or before July 23, 2015 — the 14th day after defendant GHARIB-DANESH's initial appearance in the Central District of California.
b) Counsel for defendant desires additional time to prepare for the initial status conference, including time to review the initial discovery
c) 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.
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 July 24, 2015 to August 17, 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.
5. 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.
