AMENDED STIPULATION AND ORDER TO CONTINUE FILING DEADLINES

MORRISON C. ENGLAND, Jr., District Judge.

By previous order, this matter was set for status conference on August 24, 2017, with CIPA Section 4 pleadings to be filed by June 15, 2017.

IT IS HEREBY STIPULATED by and between Phillip A. Talbert, United States Attorney, through Jill Thomas, Assistant United States Attorney, attorney for Plaintiff, Heather Williams, Federal Defender, through Assistant Federal Defender Benjamin D. Galloway, attorneys for Aws Mohammed Younis Al-Jayab, that the Government will file its first ex parte CIPA Section 4 motion by September 21, 2017. The defendant may file any ex parte statements of defense or motions to challenge the Government's ex parte CIPA Section 4 motion by September 21, 2017.

The parties further agree and stipulate, and request that the Court find the following:

a) The government has represented that the discovery associated with this case investigative reports and other documents. To date the United States has produced over 400,000 pages of unclassified discovery directly to defense counsel for review. The government has also produced a voluminous amount of classified discovery to defense counsel.

b) Counsel for defendant desires additional time to consult with his client, review the current charges, to conduct investigation and research related to the charges, to review discovery for this matter, to prepare pretrial motions, and to otherwise prepare for trial.

c) 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.

d) 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.

ORDER

The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. It specifically finds that the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court further finds that the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and defendant in a speedy trial.

The Government will file its first ex parte CIPA Section 4 Motion by September 21, 2017. The defendant may file any ex parte statements of defense or motions to challenge the Government's ex parte CIPA Section 4 motions by September 21, 2017.

IT IS SO ORDERED.