STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE

WILLIAM B. SHUBB, District Judge.

It is hereby stipulated between the parties, Brian A. Fogerty, Assistant United States Attorney, and Michael D. Long, attorney for defendant MKRTYCH SARGSYAN, that the status conference set for September 10, 2018, at 9:00 a.m. should be vacated and re-set for September 17, 2018, at 9:00 a.m.

The parties further agree that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown. Mr. Long is completing his analysis of the over 600 pages of reports and reviewing 89 discs of information, most of which are audio and video recordings. Some discs of audio recordings are presently being transcribed from Armenian in to English. Mr. Long must continue to investigate the case and meet with his client.

Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of the defendant in a speedy trial. The parties request that time to be excluded, as provided by Local Code T4 and in the Speedy Trial Act, 18 U.S.C. § 3161, et seq., from September 10, 2018 through September 17, 2018, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv). Time has already been excluded until the date of the presently set status date of September 10, 2018.

Both parties request the date of September 17, 2018, for the status hearing. The request for extending the date for the status conference is at the specific request of defendant SARGSYAN and with the knowing, intelligent and voluntary waiver of his speedy trial rights under the law. The government agrees that a continuance is necessary. Good cause is hereby shown.

ORDER

IT IS HEREBY ORDERED, the Court, having received, read, and considered the parties' stipulation, and good cause appearing therefrom, adopts the parties' stipulation in its entirety as its order. The Court specifically finds 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 finds the ends of justice are served by granting the requested continuance and outweigh the best interests of the public and defendants in a speedy trial.

The Court orders the time from the date the parties stipulated, up to and including September 17, 2018, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. §3161(h)(7)(A) and(B)(iv) [reasonable time for counsel to prepare] and General Order 479, (Local Code T4). It is further ordered the September 10, 2018 status conference for defendant SARGSYAN shall be continued until September 17, 2018, at 9:00 a.m.