STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

TROY L. NUNLEY, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, November 6, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to December 18, 2014 at 9:30 a.m. in the courtroom of the Honorable Troy L. Nunley.

The reason for this request is that additional time is needed by Ms. Radekin to complete review of discovery, for investigation, and for other defense preparation. Ms. Radekin was appointed in this case on May 13, 2014. This case involves voluminous discovery. In the last 30 days the government has provided an approximately 400 pages of additional discovery, so that discovery now ends at page number 64290. The government has also notified the defense that four boxes of additional documents are available for inspection and copying upon appointment. The Court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until December 18, 2014 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of November 6, 2014 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on December 18, 2014 at 9:30 a.m. The Court finds excludable time in this matter through December 18, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.