STIPULATION CONTINUING STATUS CONFERENCE AND PROPOSED FINDINGS REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER

GARLAND E. BURRELL, JR., Senior District Judge.

IT IS HEREBY STIPULATED by and between the defendant Lavonda Bailey, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Christopher Hales, Assistant United States Attorney, that the status conference currently set for November 15, 2019 should be continued until January 17, 2020, and to exclude time between November 15, 2019 and January 17, 2020, under Local Code T4. The parties agree and stipulate, and request that the Court find the following:

1. The government has provided discovery associated with this case, which is voluminous — i.e. approximately 14,000 pages, plus media materials, to defense counsel.

2. Given the volume of discovery, defense counsel for defendant require additional time to review the discovery in this matter, to consult with their respective clients and to conduct any necessary investigation and research related to the charges, to evaluate possible settlement, and to otherwise prepare for trial.

3. Additionally, counsel for defendant Bailey has provided evidence to the government which they are reviewing and considering which may aid in the resolution of this matter.

4. Counsel for defendant believes 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.

5. The government is unopposed to the requested continuance.

6. 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.

7. 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 appearance November 15, 2019 to January 17, 2020, inclusive, is deemed excludable pursuant to 18 U.S.C. section 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at counsel's request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the interest of the public and the defendant in a speedy trial. 8. 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 ORDERED.

Good cause appearing, the status conference presently set for November 15, 2019, at 9:00 A.M., is continued to January 17, 2020, at 9:00 A.M.. Time is excluded pursuant to the Speedy Trial Act and Local Code from November 15, 2019 to January 17, 2020 based on the stipulations set forth above by the parties and adopted by the Court.