Filed: Sep. 20, 2018
Latest Update: Sep. 20, 2018
Summary: STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR SEPTEMBER 21, 2018 TO NOVEMBER 16, 2018 GARLAND E. BURRELL, JR. , Senior District Judge . IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Christopher Hales, Assistant United States Attorney, that the status conference currently set for September 21, 2018 sh
Summary: STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR SEPTEMBER 21, 2018 TO NOVEMBER 16, 2018 GARLAND E. BURRELL, JR. , Senior District Judge . IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Christopher Hales, Assistant United States Attorney, that the status conference currently set for September 21, 2018 sho..
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STIPULATION AND PROPOSED ORDER CONTINUING THE STATUS CONFERNCE SET FOR SEPTEMBER 21, 2018 TO NOVEMBER 16, 2018
GARLAND E. BURRELL, JR., Senior District Judge.
IT IS HEREBY STIPULATED by and between the defendants, Kioni Dogan, Gloria Harris, and Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Christopher Hales, Assistant United States Attorney, that the status conference currently set for September 21, 2018 should be continued until November 16, and to exclude time between September 21, 2018 and November 16, 2018, under Local Code T4.
The parties agree and stipulate, and request that the Court find the following:
1. The government has provided discovery associated with this case, which is voluminous — i.e. approximately 14,000 pages, plus media materials, to defense counsel. Both counsel for Dogan and Harris were substituted in for original counsel and have not been counsel of record the entire time since the indictment and thus have had more limited time to prepare.
2. Given the volume of discovery, defense counsel for defendants require additional time to review the discovery in this matter, to consult with their respective clients and to conduct any necessary investigation and research related to the charges, to evaluate possible settlement, and to otherwise prepare for trial.
3. Counsel for defendants believes that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
4. The government is unopposed to the requested continuance.
5. 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. taking such action outweigh the interest of the public and the defendant in a speedy trial.
7. 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.
FINDINGS And ORDER
IT IS SO FOUND AND ORDERED.
