STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE, AND TO EXCLUDE TIME

WILLIAM B. SHUBB, District Judge.

IT IS HEREBY STIPULATED by and between Phillip A. Talbert, United States Attorney, through Brian Fogerty, Assistant United States Attorney, attorney for Plaintiff, Heather Williams, Federal Defender, through Assistant Federal Defender Sean Riordan, attorneys for Mkrtych Sargsyan, and Bruce Locke, attorney for defendant, Gagik Nersesyan, and Ruzanna Poghosyan, attorney for defendant, Oganes Emirzyan, that the status conference scheduled for April 10, 2017 be vacated and continued to July 24, 2017 at 9:00 a.m.

The Government has produced voluminous bank records and numerous foreign language audio/video files that require translation. Defense counsel for Mr. Nersesyan, Mr. Sargsyan and Mr. Emirzyan require additional time to review the discovery, to conduct additional investigation and legal research, and to confer with their clients about how to proceed in this case. Moreover, defense counsel for Mr. Sargsyan has a trial beginning April 17 that is set to last at least four weeks, a Ninth Circuit argument on May 18, and another trial scheduled to begin June 20. Accordingly, defense counsel for Mr. Sargsyan anticipates that it will be difficult finding time before early July to do additional substantial work on this case.

Based upon the foregoing, the parties agree time under the Speedy Trial Act should be excluded as of April 4, 2017, the date of the parties' stipulation, through and including July 24, 2017; pursuant to 18 U.S.C. §3161 (h)(7)(A) and (B)(iv)[reasonable time to prepare] and General Order 479, Local Code T4 based upon continuity of counsel and defense preparation.

ORDER

IT IS HEREBY ORDERED, the Court, having received, read, and considered the parties' stipulation, and good cause appearing therefrom, adopts the parties' stipulation in its entirety as its order. The Court specifically finds the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds the ends of justice are served by granting the requested continuance and outweigh the best interests of the public and defendants in a speedy trial.

The Court orders from the time of the parties' stipulation, April 4, 2017, up to and including July 24, 2017, shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and(B)(iv) [reasonable time for counsel to prepare] and General Order 479, (Local Code T4). It is further ordered the April 10, 2017 status conference shall be continued until July 24, 2017, at 9:00 a.m.