STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE, AND TO EXCLUDE TIME PURSUANT TO THE SPEEDY TRIAL ACT

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

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, Christiaan Highsmith, Assistant United States Attorney, attorney for plaintiff; Chris Haydn-Myer, attorney for defendant Farah Sarwar; and Michael E. Hansen, attorney for defendant Hussain Shahzad, that the previously-scheduled status conference date of December 4, 2014, be vacated and the matter set for status conference on December 18, 2014, at 9:00 a.m.

To date, the government has produced almost 15,000 pages of discovery. This continuance is requested to allow counsel additional time to review discovery with the defendants, to examine possible defenses and to continue investigating the facts of the case.

The Government concurs with this request.

Further, the parties agree and stipulate the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendants in a speedy trial and that time within which the trial of this case must be commenced under the Speedy Trial Act should therefore be excluded under 18 U.S.C. section 3161(h)(7)(B)(iv), corresponding to Local Codes T2 (complex case) and T4 (to allow defense counsel time to prepare), from the date of the parties' stipulation, November 25, 2014, to and including December 18, 2014.

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

IT IS SO STIPULATED.

ORDER

The Court, having received, read, and considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. Based on the stipulation of the parties and the recitation of facts contained therein, the Court finds that it is unreasonable to expect adequate preparation for pretrial proceedings and trial itself within the time limits established in 18 U.S.C. section 3161. In addition, the Court specifically finds that the failure to grant a continuance in this case would deny defense counsel to this stipulation reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.

The Court orders that the time from the date of the parties' stipulation, November 25, 2014, to and including December 18, 2014, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. section 3161(h)(7)(B)(iv), and Local Codes T2 (complex case) and T4 (reasonable time for defense counsel to prepare). It is further ordered that the December 4, 2014, status conference shall be continued until December 18, 2014, at 9:00 a.m.

IT IS SO ORDERED.