STIPULATION TO SET JURY TRIAL AND TRIAL CONFIRMATION HEARING DATES, EXCLUSION OF TIME, AND [PROPOSED] ORDER

WILLIAM B. SHUBB, District Judge.

Plaintiff United States of America, by and through its attorneys of record, Assistant United States Attorneys BRIAN A. FOGERTY and JEAN M. HOBLER, and defendants Jaime Mayorga, Ruben Rodriguez, and Christian Parada Renteria, both individually and by and through their respective counsel of record, Ronald Peters, Tim A. Pori, and Christopher Cosca, hereby stipulate as follows:

1. On August 17, 2015, the Court vacated the jury trial previously set to begin on September 22, 2015.

2. The parties jointly request that the Court set the case for a jury trial to begin on April 5, 2016, at 9:00 a.m. in Courtroom 5. The parties estimate that the trial will last three court weeks. The parties also request that the Court set the case for a trial confirmation hearing on February 29, 2016, at 9:30 a.m. in Courtroom 5.

3. On August 10, 2015, the government informed defense counsel that as part of a cooperation agreement entered with another defendant, Moctezuma Tovar, the government recently obtained 48 boxes of Delta Homes & Lending, Inc. records. Immediately, the government made these records available for review by defense counsel. However, to adequately prepare for trial, the parties agree that defense counsel will need to make arrangements to review these newly obtained materials. The parties stipulate that the time between August 31, 2015, and April 5, 2016, is required to allow the defense reasonable time to review the newly obtained documents and prepare for trial. The parties further agree that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A). Therefore, the parties request that the time between August 31, 2015, and April 5, 2016, be excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(B)(ii), (B)(iv), and Local Codes T-2 and T-4.

IT IS SO STIPULATED.

ORDER

It is hereby ORDERED that a jury trial in this case will begin on April 5, 2016, at 9:00 a.m. in Courtroom 5. The Court further ORDERS that a trial confirmation hearing shall be held on February 29, 2016, at 9:30 a.m. in Courtroom 5.

Based on the facts set forth in the parties' stipulation, the Court finds that the ends of justice served by granting a continuance from August 31, 2015, to April 5, 2016, outweigh the best interests of the public and the defendant in a speedy trial. Therefore, the time between August 31, 2015, and April 5, 2016 shall be excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(B)(ii), (B)(iv), and Local Codes T-2 and T-4.

IT IS SO ORDERED.