STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME FROM CALCULATIONS UNDER THE SPEEDY TRIAL ACT (18 U.S.C. § 3161)

WILLIAM ALSUP, District Judge.

The defendant, Ronald McGregor, represented by Brandon Leblanc, Assistant Federal Public Defender, and the government, represented by Cynthia Frey, Assistant United States Attorney, appeared before the Honorable William Alsup on January 15, 2013 for a status conference and trial setting. This Court set this matter for trial on April 8, 2013.

The parties agreed that time has continuously been excluded, including the time between June 19, 2012 and July 18, 2012 for effective preparation of counsel, but for which there is no order of exclusion. In addition, the parties agreed that time should appropriately be excluded for effective preparation of counsel from January 15, 2013 through February 5, 2013, in order to provide defense counsel with adequate time to review additional discovery, conduct additional investigation, and consult with the defendant. In addition, the defendant agrees to exclude for these periods of time any time limits applicable under 18 U.S.C. § 3161. The parties represent that granting the continuance, is necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

SO STIPULATED:

Based upon the representation of counsel and for good cause shown, the Court finds that failing to exclude the time between June 19, 2012 and July 18, 2012, as well as the time between January 15, 2013 and February 5, 2013 would unreasonably deny the defendant and counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The Court further finds that the ends of justice served by excluding the time between June 19, 2012 and July 18, 2012, as well as the time between January 15, 2013 and February 5, 2013 from computation under the Speedy Trial Act outweigh the best interests of the public and the defendant in a speedy trial.

Therefore, IT IS HEREBY ORDERED that the time between June 19, 2012 and July 18, 2012, as well as the time between January 15, 2013 and February 5, 2013 shall be excluded from computation under the Speedy Trial Act. 18 U.S.C §§ 3161(h)(7)(A), 3161(h)(7)(B)(iv).