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

GARLAND E. BURRELL, Jr., District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant Jodene Watt, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on October 17, 2014.

2. By this stipulation, defendant now moves to continue the status conference until January 9, 2015 and to exclude time between October 17, 2014 and January 9, 2015 under Local Code T4. The United States does not oppose this request.

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 investigative reports and wiretap applications in electronic form constituting approximately 4000 pages of documents. The United States also represents that the discovery includes approximately 20 CD. audio recordings, including intercepted communications, and transcripts and line reports. All of this discovery has been produced directly to counsel.

b) Counsel for defendant desires additional time to consult with his client, to conduct investigation and research related to the charges, to review discovery for this matter, to discuss potential resolutions with his client, and to otherwise prepare for trial.

c) Counsel for defendant believes that failure to grant the above-requested continuance would deny him 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 17, 2014 to January 9, 2015, 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 FOUND AND ORDERED.