LLOYD D. GEORGE, District Judge.
This matter coming on the Complex Case Scheduling Order proposed jointly by the United States and defendant FUJINAGA (hereinafter "the parties"), the premises therein considered, and good cause showing, the Court ORDERS as follows:
In accordance with the stipulation of the parties, the Court finds that this is a complex case within the meaning of 18 U.S.C. § 3161(h)(7)(B)(ii) because, among other things, the nature of the prosecution is such that it is unreasonable to expect adequate trial preparation within the time limits prescribed by the Speedy Trial Act. All time from the entry of defendant FUJINAGA's plea in this case until the trial of this matter is excluded under 18 U.S.C. § 3161(h)(7)(A), as the ends of justice outweigh the interests of the public and defendant in a speedy trial.
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The United States will make Rule 16 disclosures to defendant FUJINAGA (excluding Jencks Act and expert disclosures) on or before August 28, 2015.
Defendant FUJINAGA will make Rule 16 disclosures on or before September 25, 2015. The parties acknowledge their continuing duty to disclose up to and including trial.
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The United States will disclose Jencks Act material to defendant FUJINAGA no later than 60 days before trial.
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The United States and defendant FUJINAGA will exchange expert disclosures no later than 90 days before trial.
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The parties will file pretrial motions no later than October 30, 2015, with responses due 30 days after receipt, and optional replies due 14 days after receipt of responses.
This Proposed Schedule pertains only to defendant FUJINAGA, and imposes none of the foregoing deadlines or obligations upon the United States with respect to defendants JUNZO SUZUKI and PAUL SUZUKI.