STIPULATION AND PROPOSED ORDER TO CONTINUE INITIAL APPEARANCE OF DEFENDANT SHARON RINGGENBERG AND TO EXCLUDE TIME UNDER THE SPEEDY TRIAL ACT

JON S. TIGAR, District Judge.

The United States of America, by and through its counsel of record, and Sharon Ringgenberg, through attorney James J. Brosnahan, hereby STIPULATE and AGREE as follows:

1. On April 14, 2017, a federal grand jury in the Northern District of California returned a five-count Indictment alleging that Defendants Kenneth Taylor, Sharon Ringgenberg, and Craig Scott conspired to and that Kenneth Taylor and Sharon Ringgenberg did commit wire fraud with respect to a business providing fraudulent standby letters of credit and proof of funds statements, in violation of 18 U.S.C. §§ 1343 and 1349, and that Kenneth Taylor signed and filed false 2009 and 2010 federal income tax returns in which he failed to report income from the fraud scheme, in violation of 26 U.S.C. § 7206(1).

2. On May 22, 2017, the Court issued a Protective Order regarding the discovery materials that the government plans to serve on Defendants. See Doc. No. 17.

3. On May 25, 2017, the government served initial discovery on all defendants. The government estimates that this production contains in excess of 70,000 pages of documents.

4. On May 26, 2017, Kenneth Taylor and Craig Scott, represented by their respective counsel, and the government, represented by Assistant U.S. Attorney Colin Sampson, appeared for an initial status hearing before United States District Judge Jon S. Tigar. The matter was continued to July 21, 2017, in order for counsel to review recently-produced discovery.

Accordingly, the United States and Defendant Sharon Ringgenberg, hereby STIPULATE AND AGREE that the initial appearance of Sharon Ringgenberg before the District Court should be continued to Friday, July 21, 2017, at 9:30 a.m., and that time under the Speedy Trial Act be excluded from today until July 21, 2017, pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (b)(iv) to allow for effective preparation of counsel, taking into account the exercise of due diligence.

ORDER

Pursuant to the Stipulation of the United States of America and Defendant Sharon Ringgenberg, and for good cause shown therein, IT IS ORDERED THAT the hearing currently set for June 16, 2017, is continued to July 21, 2017, at 9:30 a.m. It is further ORDERED THAT time under the Speedy Trial Act is excluded from today until July 21, 2017, pursuant 18 U.S.C. §§ 3161(h)(7)(A) and (b)(iv) because the ends of justice outweigh the interests of the public and Defendant Sharon Ringgenberg in a speedy trial, to allow for effective preparation of counsel, taking into account the exercise of due diligence, in order for the Defendant to review discovery served upon her by the United States and to prepare any pretrial motions, among other matters.

IT IS SO ORDERED.