STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER

MORRISON C. ENGLAND, Jr., Chief District Judge.

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for a status conference on January 30, 2014, at 9:00 a.m.

2. By this stipulation, the parties move to continue the status conference until March 20, 2014, at 9:00 a.m. and to exclude time between January 30, 2014 and March 20, 2014, under Local Code T4.

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

a. The government has provided defense counsel with discovery associated with this case, which includes several law enforcement reports and audio recordings. Additional discovery has been produced, which includes several hundreds of pages of documents and additional audio recordings.

c. Based on the foregoing, defense counsel need additional time, taking into account the exercise of due diligence, to consult with their clients, to review the current charges, to conduct investigation and research related to the charges, to review discovery for this matter, to discuss potential resolutions with their clients, to prepare pretrial motions, and to otherwise prepare for trial. Based on the Court's available calendars and the availability of the parties, the parties ask that the Court set this matter for a status conference on March 20, 2014, at 9:00 a.m. and that it find excludable time from January 30, 2014 through and including the March 20, 2014 status conference. Because of the need for additional preparation outlined above, a denial of a continuance to March 20, 2014 would deny the parties the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

e. Based on the above-stated findings, the ends of justice served by continuing the case and excluding time as requested outweigh the interest of the public and the defendants 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 January 30, 2014 to March 20, 2014 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.