Filed: Jan. 17, 2020
Latest Update: Jan. 17, 2020
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order of the previously assigned judge, this matter was set for status on January 17, 2020. 2. By this stipulation, defendant now moves to continue the status conference until Ma
Summary: STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER JOHN A. MENDEZ , District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows: 1. By previous order of the previously assigned judge, this matter was set for status on January 17, 2020. 2. By this stipulation, defendant now moves to continue the status conference until Mar..
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STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
JOHN A. MENDEZ, District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through defendant's counsel of record, hereby stipulate as follows:
1. By previous order of the previously assigned judge, this matter was set for status on January 17, 2020.
2. By this stipulation, defendant now moves to continue the status conference until March 3, 2020, and to exclude time between January 17, 2020, and March 3, 2020, at 9:15 a.m., under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has provided discovery associated with this case, which is voluminous — i.e. approximately 14,000 pages, plus media materials, to defense counsel.
b) Given the volume of discovery, defense counsel for defendant require additional time to review the discovery in this matter, to consult with his client and to conduct any necessary investigation and research related to the charges, to evaluate possible settlement, and to otherwise prepare for trial.
c) Additionally, counsel for defendant has collected and provided additional 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 him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
5. The government does not object to the 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 January 17, 2020 to March 3, 2020, 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.
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 STIPULATED.
Dated: January 16, 2020 MCGREGOR W. SCOTT
United States Attorney
/s/CHRISTOPHER S. HALES
CHRISTOPHER S. HALES
Assistant United States Attorney
Dated: January 16, 2020 /s/ROBERT M. WILSON
ROBERT M. WILSON
Counsel for Defendant
LAVONDA BAILEY
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
