Filed: Aug. 07, 2018
Latest Update: Aug. 07, 2018
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsels of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on August 2, 2018. 2. By this stipulation, defendants now move to continue the status conference to October 18, 2018, and to exclude time between A
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsels of record, hereby stipulate as follows: 1. By previous order, this matter was set for status on August 2, 2018. 2. By this stipulation, defendants now move to continue the status conference to October 18, 2018, and to exclude time between Au..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER
MORRISON C. ENGLAND, JR., District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsels of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on August 2, 2018.
2. By this stipulation, defendants now move to continue the status conference to October 18, 2018, and to exclude time between August 2, 2018, and October 18, 2018, 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 150 pages of reports, 976 audio files, 204 pages of transcripts, 13,493 Google Earth files, and hundreds of pages of call logs.
b) Counsel for defendants need additional time to review the discovery, conduct investigation, interview potential witnesses, and discuss possible resolutions.
c) Counsel for defendant Gladys Mondragon was appointed on May 9, 2017.
d) Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
e) The government does not object to the continuance.
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 August 2, 2018 to October 18, 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 defendant's 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.
