STIPULATION BETWEEN THE PARTIES TO CONTINUE THE STATUS CONFERENCE TO FRIDAY, NOVEMBER 18, 2016 WITH EXCLUSION OF TIME FROM THE SPEEDY TRIAL ACT AND PROPOSED ORDER

GARLAND E. BURRELL, Jr., Senior District Judge.

The parties to this litigation, the United States of America, represented by Assistant United States Attorney, Michele M. Beckwith, and for the defendant, Steven B. Plesser representing Arsen Muhtarov, hereby agree and stipulate to the following1:

1-By previous order, this matter was set for status on Friday, August 19, 2016.

2. By this Stipulation, the parties now move to continue the status conference until Friday, November 18, 2016 and to exclude time pursuant to the Speedy Trial Act between Friday, August 19, 2016 and Friday, November 18, 2016, under Local Code T-4 (time for adequate attorney preparation). The government, to date, has produced discovery of more than approximately 15,300 pages in this case and has informed Defendant that additional discovery will be produced this week.

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

a. The government has produced initial discovery to date which consists of approximately over 15,300 pages and is still in the process of producing additional discovey.

b. Counsel for defendant needs additional time to continue to review all the discovery — including that which is still forthcoming — with his client, to continue investigation into this case, continue to do research, which includes legal research, in this case, and to otherwise continue to do review and investigation, using due diligence, that this complex case requires.

c. The Government and defense are discussing possible resolution and additional time is needed to discuss possible plea agreement, taking into account new discovery.

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

e. The government, based on all of the above, concurs in the need for a continuance.

f. To ensure continuity of counsel, and to allow sufficient time for discussions by and with and between the government and defendant about the case and to explore any potential for possible resolution, in the exercise of reasonable diligence the continuance of the status conference is reasonable.

g. 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.

h. For the purpose of computing the time under the Speedy Trial Act, Title 18 U.S.C. section 3161, et seq., within which trial must commence, the time period from Friday, August 19, 2016 to Friday, November 18, 2016, inclusive, is deemed excludable pursuant to Title 18 U.S.C. section 3161(h)(7)(B)(iv) corresponding to Local Code T-4, because it results from a continuance granted by the Court at defendant's request on the basis of the Court's finding that due to the amount of discovery and potential legal issues in the case 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.

Each attorney has granted Steven B. Plesser full authority to sign for each individual attorney.

[PROPOSED] ORDER

IT IS SO FOUND AND ORDERED.