STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS HEARING DATE TO JUNE 1, 2018 AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT

JON S. TIGAR, Magistrate Judge.

The above-captioned matter is set on May 4, 2018 before this Honorable Court for a status hearing. The parties jointly request that the Court continue this matter to June 1, 2018, at 9:30 a.m., for a status hearing and that the Court exclude time under the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), through June 1, 2018.

On September 28, 2017, Mr. Redic was charged with sex trafficking by force, threats or coercion, a violation of 18 U.S.C. § 1591(a)(1). Mr. Redic made his initial appearance the next day, on September 29, 2017. After a full detention hearing, on October 11, 2017, the magistrate court ordered Mr. Redic detained. Mr. Redic is facing a mandatory minimum sentence of 15 years in federal custody.

The government produced discovery, including a production in late November 2017. In letters dated January 12, 2018, March 15, 2018 defense counsel requested additional discovery from the government, which includes video interviews of witnesses and an alleged victim. In addition, following a defense evidence view, the defense made a supplemental discovery request on April 25, 2018. The government is in the process of gathering materials responsive to the defense requests and will determine if the requested materials can be produced to the defense. In addition, government counsel is assessing whether or not grand jury materials can be shared with the defense. Once produced, defense counsel will need additional time to review all of the discovery and to further investigate this case. Moreover, defense counsel continues to research and to investigate complicated legal issues implicated by this case, including the commerce clause and statutory and other sentencing enhancements.

The parties stipulate and agree that the ends of justice served by this continuance outweigh the best interest of the public and the defendant in a speedy trial. The parties further agree that the failure to grant this continuance would unreasonably deny counsel for defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Accordingly, the parties agree that the period of time through June 1, 2018, should be excluded in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), for effective preparation of defense counsel, taking into account the exercise of due diligence.

[PROPOSED] ORDER

Based on the reasons provided in the stipulation of the parties above, and for good cause shown, the Court hereby ORDERS that the status hearing date of May 4, 2018, is vacated and reset for status on June 1, 2018, at 9:30 a.m. It is FURTHER ORDERED that time is excluded, pursuant to the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), through June 1, 2018.