Opinion
Bruce Locke (#177787) Moss & Locke Attorneys for Artur Arshakyan
For DOUGLAS BEEVERS Attorney for Stella Avetisyan
For MICHAEL CHASTAINE Attorney for Elijah Simonyan
For Jared Dolan Attorney for the United States
Morrison C. England, Jr. Chief Judge
IT IS HEREBY STIPULATED AND AGREED between the defendants, Elijah Simonyan, Stella Avetisyan, and Artur Arshakyan, by and through their undersigned defense counsel, and the United States of America, by and through its counsel, Assistant U.S. Attorney Jared Dolan, that the status conference presently set for January 15, 2015 at 9:00 a.m., should be continued to March 26, 2015 at 9:00 a.m., and that time under the Speedy Trial Act should be excluded from January 15, 2015 through March 26, 2015.
The reason for the continuance is that the defense needs additional time to conduct pretrial investigation, to review recently provided discovery, to complete potential plea negotiations; and to prepare for trial. The exclusion of time is also necessary to ensure continuity of counsel. Accordingly, the time between January 15, 2015 and March 26, 2015 should be excluded from the Speedy Trial calculation pursuant to Title 18, States Code, Section 3161(h)(7)(B)(iv) and Local Code T-4 for defense preparation. The parties stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. 18 U.S.C. §3161(h)(7)(A). Mr. Dolan, Mr. Beevers and Mr. Chastaine have authorized Mr. Locke to sign this pleading for them.
IT IS SO ORDERED.