STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ORDER

MORRISON C. ENGLAND, Jr., District Judge.

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on June 29, 2017.

2. By this stipulation, the defendant now moves to continue the status conference until July 27, 2017, and to exclude time between June 29, 2017, and July 27, 2017, 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 investigative reports and related documents, accounting and bank records, tax filings, and other relevant documents, totaling 54,939 pages to date. All of this discovery has been produced directly to counsel for the defendant.

b) The parties anticipate setting trial and pre-trial motion briefing dates at their next court appearance in this matter.

c) Counsel for the defendant desires additional time to investigate the case, discuss potential pre-trial motions with his client, conduct additional legal and factual research, and review and analyze the voluminous discovery in this matter.

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

e) The government does not oppose the request for a continuance based on the amount of discovery, the need for defense preparation, and the parties' commitment to setting trial and briefing dates at the July 27, 2017 status conference.

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 June 29, 2017 to July 27, 2017, 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.

ORDER

IT IS SO ORDERED.