FACTUAL FINDINDS PURSUANT TO 18 U.S.C. § 3161(h)(7)

JEFFREY T. MILLER, District Judge.

At the status hearing held on May 6, 2016, the parties in this case agreed that this case is unusually complex, such that it is unreasonable to expect counsel for the defendant to prepare for pretrial proceedings and for trial within the time limits established by Title 18, United States Code, Section 3161. Accordingly, the Court hereby excludes the following time period under the Speedy Trial Act: from May 6, 2016, to July 22, 2016. See United States v. Ramirez-Cortez, 213 F.3d 1149, 1154 (9th Cir. 2000). Further, in support of its complexity determination, the Court hereby makes the following factual findings pursuant to Title 18, United States Code, Section 3161(h)(7)(A) and 3161(h)(7)(B):

(1) The charge against defendant Antonio Reynoso-Gonzalez ("Reynoso") and his twenty-two codefendants stems from an investigation conducted over multiple years and in multiple jurisdictions. The investigation utilized court-authorized electronic surveillance in several cities, including Los Angeles, Chicago and San Antonio. In addition to judicial districts within the United States, the indictment alleges the commission of overt acts in Mexico. The time frame of the conspiracy alleged in the indictment spans a period of over five years, ending in June 1995. Additionally, defendant Reynoso was extradited from Mexico to the United States to face the charge in this case. As such, this case is unusually complex, in that it raises novel questions of fact and law.

(2) To date, the Government has provided defendant Reynoso with over 37,000 pages of written discovery materials.

(3) The thousands of wiretap calls intercepted during the investigation were recorded on cassette tapes. The Government has converted the cassette tapes to more readily-usable compact disks. The vast majority of the intercepted conversations are in the Spanish language. Defendant Reynoso has identified approximately 50 to 60 intercepted calls in which he is a participant, which must be translated from Spanish to English. Defendant Reynoso has also identified approximately 10 to 20 additional calls he wishes to have translated and transcribed before filing additional pretrial motions.

(4) Given the scope of the indictment, the unusually large volume of the written discovery materials and the thousands of Spanish language wiretap calls which must be reviewed by the defense, it would be unreasonable to expect counsel for defendant Reynoso to adequately prepare for pretrial proceedings and the trial itself within the time limits established by the Speedy Trial Act despite the exercise of due diligence.