Filed: Jun. 22, 2016
Latest Update: Jun. 22, 2016
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, Jr. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on June 23, 2016. 2. By this stipulation, defendant now moves to continue the status conference until July 14, 2016, and to exclude time betwee
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, Jr. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on June 23, 2016. 2. By this stipulation, defendant now moves to continue the status conference until July 14, 2016, and to exclude time between..
More
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER
MORRISON C. ENGLAND, Jr., District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on June 23, 2016.
2. By this stipulation, defendant now moves to continue the status conference until July 14, 2016, and to exclude time between June 23, 2016, and July 14, 2016, under Local Code T-4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the discovery associated with this case includes investigative reports and other documents. To date the United States has produced approximately 283,000 pages of unclassified discovery directly to defense counsel for review. The United States continues to regularly produce unclassified discovery and is coordinating access to a voluminous amount of classified discovery for 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/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 23, 2016 to July 14, 2016, 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.
g) The Court has previously found this matter to be complex within the meaning of 18 U.S.C. § 3161(h)(7)(b)(ii) [Local Code T-2]. The parties stipulate that exclusion of time continues to be appropriate under Local Code T-2.
h) Additionally, the defendant is pending trial on other charges in the Northern District of Illinois and this Court has previously excluded time on this basis pursuant to 18 U.S.C. § 3161(h)(1)(B) [Local Code M]. The parties stipulate that exclusion of time continues to be appropriate under Local Code M.
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.
ORDER
IT IS SO ORDERED.
