Filed: Apr. 26, 2019
Latest Update: Apr. 26, 2019
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION 1. By previous order, this matter was set for status on April 25, 2019. 2. By this stipulation, defendants now move to continue the status conference until June 20, 2019, and to exclude time between April 25, 2019, and June 20, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a) The government has
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER MORRISON C. ENGLAND, JR. , District Judge . STIPULATION 1. By previous order, this matter was set for status on April 25, 2019. 2. By this stipulation, defendants now move to continue the status conference until June 20, 2019, and to exclude time between April 25, 2019, and June 20, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a) The government has ..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER
MORRISON C. ENGLAND, JR., District Judge.
STIPULATION
1. By previous order, this matter was set for status on April 25, 2019.
2. By this stipulation, defendants now move to continue the status conference until June 20, 2019, and to exclude time between April 25, 2019, and June 20, 2019, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has produced voluminous discovery in this case to all parties. This discovery includes nearly 20,000 pages of reports, business records, bank records, photographs, and Excel spreadsheets. It also includes over 15 compact discs containing media and electronic files.
b) Counsel for Russell White, III recently entered the case. Counsel for defendants desire additional time to review the voluminous and complex discovery for this matter, conduct investigation and research related to the charges, to consult with their clients, and to otherwise prepare for trial.
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 government 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 April 25, 2019 to June 20, 2019, 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.
Dated: April 23, 2019 McGREGOR SCOTT
United States Attorney
/s/AMY HITCHCOCK
AMY HITCHCOCK
Assistant United States Attorney
Dated: April 23, 2019. /s/DAVID D. FISCHER
DAVID D. FISCHER
Counsel for Defendant
RUSSELL WHITE, III
Dated: April 23, 2019. /s/TIM ZINDEL
TIM ZINDEL
Counsel for Defendant
PAMELA EMANUEL
ORDER
IT IS SO ORDERED.
