Filed: Jun. 09, 2016
Latest Update: Jun. 09, 2016
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER GARLAND E. BURRELL, Jr. , Senior District Judge . STIPULATION 1. By previous order, this matter was set for status on June 17, 2016. 2. By this stipulation, the parties now move to continue the status conference until August 26, 2016, and to exclude time between June 17, 2016, and August 26, 2016, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER GARLAND E. BURRELL, Jr. , Senior District Judge . STIPULATION 1. By previous order, this matter was set for status on June 17, 2016. 2. By this stipulation, the parties now move to continue the status conference until August 26, 2016, and to exclude time between June 17, 2016, and August 26, 2016, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the f..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER
GARLAND E. BURRELL, Jr., Senior District Judge.
STIPULATION
1. By previous order, this matter was set for status on June 17, 2016.
2. By this stipulation, the parties now move to continue the status conference until August 26, 2016, and to exclude time between June 17, 2016, and August 26, 2016, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has produced approximately 31,347 pages of discovery directly to defense counsel in this matter to date. This discovery consists of investigative reports, audio recordings, banking records, escrow files, loan files, various subpoena returns, and other documents obtained or created in the course of the investigation. Moreover, defense counsel have been informed that the government is in possession of an imaged hard drive ready for defense counsel's inspection and copying at a time of their choosing.
b) Counsel for defendants desire additional time to review this voluminous discovery, consult with their respective clients, conduct investigation and research, and to otherwise evaluate the case and prepare for trial.
c) 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.
d) The government joins in the request for a continuance so that all parties will be prepared to set trial dates at the proposed August 26, 2016, status conference.
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 June 17, 2016 to August 26, 2016, 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 the parties' 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.
[PROPOSED] FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
