The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ) [PROPOSED] FINDINGS AND ) ORDER
Judge: Hon. Garland E. Burrell
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through her counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on November 2, 2012.
2. By this stipulation, defendant now moves to continue the status conference until November 30, 2012 and to exclude time between November 2, 2012 and November 30, 2012 under Local Code T4. Plaintiff does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a. The government has represented that the discovery associated with this case includes six recordings in Russian, approximately 2780 pages of discovery which includes numerous bank records and mortgage loan documents, as well as witness interviews. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b. Counsel for defendant desires additional time to have the recordings in Russian translated and transcribed. Previously, defense counsel had obtained authorization for the translation of the recordings. The interpreter has these recordings, but had some difficulty accessing them in a manner that allowed him to begin the transcription. This issue has been resolved and he has begun the transcription, however he needs more time to finish the project. Counsel for defendant also desires additional time to consult with her client, to review the current charges, to finish the investigation and research related to the charges, to finish ongoing investigation, and to discuss potential resolutions with her client.
c. Counsel for defendant believes that failure to grant the above-requested continuance would deny her 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 ...