Filed: Jun. 10, 2019
Latest Update: Jun. 10, 2019
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION The defendant, Nassir Michaels, by and through his counsel, Toni White, and the Government, by and through its counsel, Vincenza Rabenn, hereby stipulate as follows: 1. By previous order, this matter was set for status on June 11, 2019 2. By this stipulation, defendant now moves to continue the status conference until August 6, 2019 at 9:15 a.m. and to exclude time bet
Summary: STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION The defendant, Nassir Michaels, by and through his counsel, Toni White, and the Government, by and through its counsel, Vincenza Rabenn, hereby stipulate as follows: 1. By previous order, this matter was set for status on June 11, 2019 2. By this stipulation, defendant now moves to continue the status conference until August 6, 2019 at 9:15 a.m. and to exclude time betw..
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STIPULATION REGARDING CONTINUANCE OF STATUS CONFERENCE; FINDINGS AND ORDER
JOHN A. MENDEZ, District Judge.
STIPULATION
The defendant, Nassir Michaels, by and through his counsel, Toni White, and the Government, by and through its counsel, Vincenza Rabenn, hereby stipulate as follows:
1. By previous order, this matter was set for status on June 11, 2019
2. By this stipulation, defendant now moves to continue the status conference until August 6, 2019 at 9:15 a.m. and to exclude time between June 11, 2019, and August 6, 2019, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) Discovery is ongoing. Currently, defense counsel is in possession of 196 Bates Stamped pages as well as 39 DVDs containing video and audio files.
b) Counsel for defendant desires this time to continue to review discovery, to continue to consult with her client, review the current charges, conduct investigation and research related to the charges and to discuss potential resolutions with her client and otherwise prepare for trial.
c) Counsel for defendant believes that failure to grant the above-requested continuance would deny 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 June 11, 2019 to August 6, 2019, 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.
4. 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.
Dated: June 7, 2019 PHILLIP A. TALBERT
Acting United States Attorney
/s/VINCENZA RABENN
VINCENZA RABENN
Assistant United States Attorney
Dated: June 7, 2019. /s/TONI WHITE
TONI WHITE
Counsel for Defendant
NASSIR MICHAELS
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
