STIPULATION TO CONTINUE SECOND STATUS CONFERENCE AND REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER

SHEILA K. OBERTO, Magistrate Judge.

TO THE ABOVE-CAPTIONED COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

STIPULATION

Plaintiff UNITED STATES OF AMERICA, by and through its counsel of record, and Defendants BAHAR GHARIB-DANESH, NA YOUNG EOH, and JOHN THOMAS TERRENCE (hereafter referred to collectively as "Defendants"), by and through their counsel of record, hereby stipulate as follows:

1. All parties appeared before the Honorable Sheila K. Oberto on August 17, 2015 for a First Status Conference. At that time, a Second Status Conference was scheduled for November 30, 2015, at 1:00 p.m., before the Honorable Sheila K. Oberto. The parties stipulated to continue this Second Status Conference to February 16, 2016, and the Court signed the Order. The parties now move to continue this Second Status Conference to April 4, 2016 at 1:00 p.m.

2. By this stipulation, Defendants now move to continue the Second Status Conference until April 4, 2016, at 1:00 p.m., and to exclude time between August 17, 2015 and April 4, 2016, under 18 U.S.C. § 3161(h)(7)(A), (B)(iv).

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

(a) The government has produced approximately 88,000 pages of written discovery.

(b) Counsel for Defendants desire additional time to prepare for the Second Status Conference, including time to further review discovery furnished by the government.

(c) Counsel for Defendants believe that failure to grant the above-requested continuance would deny their clients the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

(d) There is no objection 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 defendants in a trial within the original date prescribed by the Speedy Trial Act.

(f) For purposes of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of August 17, 2015 to April 4, 2016, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(A), (B)(iv) 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 defendants 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 ORDERED.