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 October 26, 2017.

2. By this stipulation, defendant now moves to continue the status conference until December 14, 2017, and to exclude time between October 26, 2017, and December 14, 2017, under Local Code T4. The United States does not oppose.

3. The parties agree and stipulate, and request that the Court find the following:

a) The United States has represented that the discovery associated with this case includes email correspondence, transcripts of interviews, corporate records, and other documents that constitutes over million pages of discovery. The United States has directly produced to counsel for inspection and copying.

b) The parties have begun discussions with respect to the potential resolution of this case, and it is anticipated that the United States will be providing the defendant a plea offer within the next few weeks. Counsel for defendant will need time to conduct research relating to the terms of the plea, and review discovery in relation to the plea, as well as 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 United States 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 October 26, 2017 to December 14, 2017, 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.

ORDER

IT IS SO ORDERED.