Filed: May 10, 2019
Latest Update: May 10, 2019
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER TIME: 9:15 a.m. COURT: JOHN A. MENDEZ , District Judge . STIPULATION 1. By previous order, this matter was set for status on May 14, 2019. 2. By this stipulation, defendants now move to continue the status conference until June 4, 2019 at 9:15 a.m., and to exclude time between May 14, 2019, and June 4, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER TIME: 9:15 a.m. COURT: JOHN A. MENDEZ , District Judge . STIPULATION 1. By previous order, this matter was set for status on May 14, 2019. 2. By this stipulation, defendants now move to continue the status conference until June 4, 2019 at 9:15 a.m., and to exclude time between May 14, 2019, and June 4, 2019, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the f..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER TIME: 9:15 a.m. COURT:
JOHN A. MENDEZ, District Judge.
STIPULATION
1. By previous order, this matter was set for status on May 14, 2019.
2. By this stipulation, defendants now move to continue the status conference until June 4, 2019 at 9:15 a.m., and to exclude time between May 14, 2019, and June 4, 2019, 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 from multiple agencies, court documents, photographs, voluminous electronic materials, and various other documents. To date, the United States has made this discovery available to the defense and is prepared to make rolling physical productions contingent upon the execution of a protective order that will protect defendants' and others' personal identifying information.
b) Counsel for defendants desire additional time to review discovery, consult with their clients, conduct investigation and research related to the charges, discuss potential resolutions with their clients and to otherwise prepare for trial, if necessary. They 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.
c) The government does not object to the continuance.
d) 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.
e) 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 May 14, 2019 to June 4, 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 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.
Dated: May 10, 2019 Respectfully Submitted,
/s/Dustin D. Johnson
DUSTIN D. JOHNSON
Attorney for Defendant
Kimberley Robinson
Dated: May 10, 2019 /s/Dustin D. Johnson for
Robert M. Wilson
ROBERT M. WILSON
Attorney for Defendant
Brian Robinson
Dated: May 10, 2019 /s/Dustin D. Johnson for Mark S. Axup
MARK S. AXUP
Attorney for Defendant
Cuc Thi Schaeffer
Dated: May 10, 2019 /s/Dustin D. Johnson for Todd Leras
TODD LERAS
Attorney for Defendant
Antonio Gonzalez
Dated: May 10, 2019 /s/Dustin D. Johnson for
Hayes H. Gable
HAYES H. GABLE
Attorney for Defendant
John Acosta
Dated: May 10, 2019 McGREGOR W. SCOTT
United State Attorney
/s/Dustin D. Johnson for
Michele Beckwith
MICHELE BECKWITH
Assistant United State Attorney
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
