STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

WILLIAM B. SHUBB, District Judge.

COMES NOW the parties, by and through their attorneys of record James A. Lassart from the law firm of Murphy, Pearson, Bradley & Feeney, and Assistant United States Attorney Roger Yang, from the United States Attorney's Office, jointly stipulate and move to continue the Status Conference currently set for June 24, 2019 at 9:00 a.m. to September 9, 2019 at 9:00 a.m. and to exclude time under Local Code T4.

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

1. Counsel for the defendant needs additional time to go through the discovery and meet with the client, as well as to conduct their own investigation. Discovery in this matter is voluminous, consisting of 14,430 Bates stamped pages. There are also 2 video and audio CDs. Defense counsel needs time to continue reviewing discovery, to continue to consult with his client, to review the current charges, to conduct investigation and research related to the charges and to discuss potential resolutions with his client and otherwise prepare for trial.

2. Defense counsel believes that failure to grant the above-requested continuance would deny him reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

3. The government does not object to the continuance.

4. 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.

5. 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 24, 2019 to September 9, 2019 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.

6. 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

IT IS SO ORDERED.