STIPULATION CONCERING STATUS CONFERENCE AND EXCLUDABLE TIME UNDER SPEEDY TRIAL ACT; [PROPOSED] ORDER

GARLAND E. BURRELL, Jr., District Judge.

Defendant Mark Friend, by and through his counsel of record, Malcolm Segal, Segal & Associates, PC and Plaintiff United States of America, by and through its counsel of record, hereby stipulate as follows.

1. By previous order made at the time of defendant's arraignment, a status conference was scheduled in this matter on June 19, 2015 at 9:00 a.m.

2. Since the time of the Court's previous order on May 15, 2015, the parties have engaged in the following:

a. Prior to commencing the discovery process, the parties prepared a written stipulation and proposed protective order concerning discovery materials. The signed stipulation was filed and the protective order was signed by the Court on May 28, 2015.

b. On May 15, 2015, the government provided defense counsel with 41 CD's containing various investigative materials. The materials are voluminous and defense counsel continues in the process of accessing and organizing the materials for a more thorough review and analysis.

c. Counsel for defendant also expects the government to produce additional discovery materials, including investigative reports.

3. The defense requires additional time to undertake a full review of all relevant documents. Counsel for defendant believes that 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. The United States does not object to the requested continuance.

4. By this stipulation the parties request that the status conference be continued until August 21, 2015 at 9:00 a.m., and for the time between June 19, 2015, and August 21, 2015, to be excluded under Local Code T4.

5. Based on the foregoing, the parties agree that 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 time prescribed by the Speedy Trial Act. 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 from June 19, 2015 to 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 interest of the public and the defendant in a speedy trial. 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.

[PROPOSED] ORDER

IT IS HEREBY ORDERED that the Status Conference scheduled for June 19, 2015, is continued to August 21, 2015 at 9:00 a.m.

It is further ORDERED that under the Speedy Trial Act the time between June 19, 2015 and August 21, 2015, inclusive, is hereby excluded under Local CodeT4, and 18 U.S.C.§§ 3161(h)(7)(A), B(iv), to ensure adequate time for preparation of counsel. For the reasons set forth above, the court finds that the ends of justice served by a continuance outweigh the best interests of the public and the defendant in a speedy trial and therefore excludes time through August 21, 2015.