Opinion
AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
STIPULATION
1. By previous order, this matter was set for status on June 4, 2015.
2. By this stipulation, the defendants now move to continue the status conference until June 18, 2015, and to exclude time between June 4, 2015, and June 18, 2015, under Local Code T4.
BENJAMIN B. WAGNER, United States Attorney, HEIKO P. COPPOLA, Assistant United States Attorney Sacramento, CA, Attorneys for Plaintiff United States of America.
CHRISTOPHER BOOTH, Counsel for Defendant HERMAN KEESE.
MICHAEL CHASTAINE, Counsel for Defendant DEBORAH BARNES.
CLEMENTE M. JIMENEZ, Counsel for Defendant JAMES BRADLEY.
DAVID FISCHER, Counsel for Defendant BRETT TOWNSEND.
3. The parties agree and stipulate, and request that the Court find the following:
a) The discovery associated with this case is voluminous, consisting of hundreds of pages of discovery and several dozen hours of audio recordings. Negotiations related to resolution of the case short of trial have begun and are on-going.
b) Counsel for defendants desire additional time to review the discovery provided, perform investigation and confer with their respective clients.
c) Counsel for defendants believe 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 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.
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 June 4, 2015 to June 18, 2015, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A) and 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 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.
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.