Filed: Jan. 24, 2020
Latest Update: Jan. 24, 2020
Summary: STIPULATION AND [PROPOSED] FINDINGS AND ORDER TO CONTINUE STATUS CONFERENCE UNDER SPEEDY TRIAL ACT WILLIAM B. SHUBB , District Judge . STIPULATION 1. By previous order, this matter was set for status on January 27, 2020. 2. By this stipulation, defendants now move to continue the status conference until March 9, 2020, and to exclude time between January 27, 2020 and March 9, 2020, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a
Summary: STIPULATION AND [PROPOSED] FINDINGS AND ORDER TO CONTINUE STATUS CONFERENCE UNDER SPEEDY TRIAL ACT WILLIAM B. SHUBB , District Judge . STIPULATION 1. By previous order, this matter was set for status on January 27, 2020. 2. By this stipulation, defendants now move to continue the status conference until March 9, 2020, and to exclude time between January 27, 2020 and March 9, 2020, under Local Code T4. 3. The parties agree and stipulate, and request that the Court find the following: a...
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STIPULATION AND [PROPOSED] FINDINGS AND ORDER TO CONTINUE STATUS CONFERENCE UNDER SPEEDY TRIAL ACT
WILLIAM B. SHUBB, District Judge.
STIPULATION
1. By previous order, this matter was set for status on January 27, 2020.
2. By this stipulation, defendants now move to continue the status conference until March 9, 2020, and to exclude time between January 27, 2020 and March 9, 2020, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a. The government produced discovery associated with this case. The discovery thus far consists of over 43,000 pages, that have been provided to counsel. In addition, the government has also made physical evidence available for review, which includes several hard drives that were seized during the service of the search warrants.
b. Counsel has met with Ms. Lee but needs additional time to finish reviewing the discovery with the client and continue ongoing settlement negotiations with the government.
c. 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.
d. The government does not object to the continuance.
e. Based upon the above-stated facts, 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 January 27, 2020, to March 9, 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 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 provision 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 23, 2020 Respectfully submitted,
/s/ Kelly Babineau
KELLY BABINEAU
Attorney for Karen Lee
Dated: January 23, 2020 /s/ Heiko Coppola
HEIKO COPPOLA
Assistant U.S. Attorney
[PROPOSED] FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
