STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

LAWRENCE K. KARLTON, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas, and defendant, Angela Shavlovsky, by and through her counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, August 12, 2014 at 9:15 a.m., in the above-captioned matter, and to continue the status conference to September 16, 2014 at 9:15 a.m. in the courtroom of the Honorable Lawrence K. Karlton.

The reason for this request is that additional time is needed by Ms. Radekin to complete review of discovery, which is voluminous (discovery currently ends with item/page number 63026, counsel has reviewed through 7078 as of this date) and includes a number of recordings. There is also additional defense preparation and investigation Ms. Radekin needs to complete. The Court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until September 16, 2014 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of August 12, 2014 at 9:15 a.m. is VACATED and the above-captioned matter is set for status conference on September 16, 2014 at 9:15 a.m. The Court finds excludable time in this matter through September 16, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.