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 January 5, 2018.

2. By this stipulation, defendants Jagdish Singh, Tajinder Singh, Parminder Singh, and Shawana Denise Harris,1 through their respective counsel of record, now move to continue the status conference until February 23, 2018, and to exclude time between January 5, 2018, and February 23, 2018, under Local Code T4.

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

a) The United States has represented that the discovery associated with this case includes will include, collectively, investigative reports, electronic discovery obtained from the search of various electronic devices, records from the California Department of Motor Vehicles, and records from telephone providers and banks. The parties are presently discussing a protective order to govern discovery in this case, and anticipate that discovery will be produced shortly upon completion and execution of the protective order.

b) Counsel for defendants desire additional time consult with their respective clients, to review the current charges, to conduct investigation and research related to the charges, to discuss potential resolutions with his/her client, to prepare pretrial motions, and to otherwise prepare for trial. They will also need time to review discovery upon its receipt.

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 United States does not object to the continuance.

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 January 5, 2018 to February 23, 2018, 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 defendants' 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.

FINDINGS AND ORDER

IT IS SO FOUND AND ORDERED.