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

JOHN A. MENDEZ, District Judge.

STIPULATION

1. By previous order, this matter was set for status on September 22, 2015.

2. By this stipulation, defendants now move to continue the status conference until December 8, 2015 at 9:15 a.m., and to exclude time between September 22, 2015, and December 8, 2015 at 9:15 a.m., under Local Code T4.

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

a) The government has represented that the discovery associated with this case includes 700 pages of interview reports and documents obtained through the investigation and 90 discs containing audio and video files. All of this discovery has been produced directly to counsel.

b) Further, the United States represents that additional discovery, including DMV records and information from cellular phones seized during the course of the investigation is still be processed for discovery and the United States anticipates such discovery will be produced over the next several weeks.

c) Counsel for defendants desire additional time need additional time to review the discovery and investigate the case, including to conduct legal research as to any potential defenses, and to discuss the matter with their clients.

d) Counsel for defendants believe that failure to grant the above-requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

e) The government does not object to the continuance.

f) 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.

g) 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 September 22, 2015 to December 8, 2015 at 9:15 a.m., 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 defendants' 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.

FINDINGS AND ORDER

IT IS SO FOUND AND ORDERED.