STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE

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

STIPULATION

IT IS HEREBY STIPULATED by and between Phillip A. Talbert, United States Attorney, through Jared Dolan, Assistant United States Attorney, attorney for Plaintiff, on the one hand, and David Fischer, attorney for defendant Jonathan Ganey, on the other hand, that the status conference scheduled for October 27, 2017, at 9:00 a.m. be continued to November 3, 2017, at 9:00 a.m.

The parties are working to determine whether a plea agreement can be reached. There are over 1380 pages of discovery, and numerous audio and video recordings. The defense has provided an expert report to the government for its consideration in this case.

Based upon the foregoing, the parties agree that the Court should find and order: (1) the failure to grant the requested continuance would deny counsel for defendants reasonable time necessary for effective preparation, taking into account the exercise of due diligence; (2) in computing time under the Speedy Trial Act within which the trial of this matter must be commenced, time should be excluded from the date of this stipulation, October 26, 2017, through and including the November 3, 2017, hearing date pursuant to Local Code D, as well as 18 U.S.C. §3161 (h)(7)(A) and (B)(iv) [reasonable time to prepare] and General Order 479, Local Code T4 based upon and defense preparation; and (3) the ends of justice served by taking such action in granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.

The Court having received, read, and considered the stipulation between the United States of America and defendant Jonathan Ganey, and good cause appearing therefrom, adopts the stipulation and proposed findings in their entirety as its Order.

IT IS SO ORDERED.