STIPULATION FOR EXTENSION OF TIME FOR PRELIMINARY HEARING PURSUANT TO RULE 5.1(D) AND EXCLUSION OF TIME AND [PROPOSED] FINDINGS AND ORDER

CAROLYN K. DELANEY, Magistrate Judge.

Plaintiff United States of America, by and through its attorney of record, Special Assistant U.S. Attorney ROBERT J. ARTUZ, and Defendant, Monica Nunes, both individually and by and through her counsel of record, Christina Sinha, hereby stipulate as follows:

1. The Complaint in this case was filed on April 4, 2019, and Defendant Monica Nunes first appeared before a judicial officer of the Court in which the charges in this case were pending on April 19, 2019. On that date, the Court set a preliminary hearing date of May 3, 2019. The parties then stipulated to have the preliminary hearing continued to May 31, 2019, and additional times to June 28, 2019, and July 18, 2019. ECF 8, 13, 15.

2. By this stipulation, the parties jointly move for an additional extension of time of the preliminary hearing date to August 8, 2019, at 2:00 p.m., before the duty Magistrate Judge, pursuant to Rule 5.1(d) of the Federal Rules of Criminal Procedure. The parties stipulate that the delay is required to allow the defense reasonable time for preparation, and for the government's continued collection and production of discovery and continuing investigation of the case. For example, the government is continuing to collect and produce audio/video files and hundreds of pages of bank records, forensic data, witness statements, subpoena returns, and police reports relevant to this case. Defense counsel needs additional time to review and consider this evidence and to conduct additional investigation. The parties further agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

3. The parties agree that good cause exists for the extension of time, and that the extension of time would not adversely affect the public interest in the prompt disposition of criminal cases. Therefore, the parties request that the time between July 18, 2019, and August 8, 2019, be excluded pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv), Local Code T-4.

IT IS SO STIPULATED.

FINDINGS AND ORDER EXTENDING TIME FOR PRELIMINARY HEARING PURSUANT TO RULE 5.1(d) AND EXCLUDING TIME

The Court has read and considered the Stipulation for Extension of Time for Preliminary Hearing Pursuant to Rule 5.1(d) and Exclusion of Time, filed by the parties in this matter on July 9, 2019. The Court hereby finds that the Stipulation, which this Court incorporates by reference into this Order, demonstrates good cause for an extension of time for the preliminary hearing date pursuant to Rule 5.1(d) of the Federal Rules of Criminal Procedure.

Furthermore, for the reasons set forth in the parties' stipulation, the Court finds that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A). The Court further finds that the extension of time would not adversely affect the public interest in the prompt disposition of criminal cases.

THEREFORE, FOR GOOD CAUSE SHOWN:

1. The date of the preliminary hearing is extended to August 8, 2019, at 2:00 p.m.

2. The time between July 18, 2019, and August 8, 2019, shall be excluded from calculation pursuant to 18 U.S.C. § 3161(h)(7)(A).

3. Defendants shall appear at that date and time before the Magistrate Judge on duty.

IT IS SO ORDERED.