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United States of America v. Jason Samuel Schroeder

May 15, 2013

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JASON SAMUEL SCHROEDER, ET AL., DEFENDANTS.



The opinion of the court was delivered by: John A. Mendez United States District Court Judge

STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendants, by and through their counsel of record, hereby stipulate as follows:

1. The Court previously set this matter for a status conference on June 5, 2013 and excluded time under Local Code T4 until that date.

2. On May 14, 2013, the Court signed a related case order and vacated the previously scheduled status conference

3. By this stipulation, defendants now move to set a status conference on July 9, 2013 at 9:45 a.m. and to exclude time from June 5, 2013 until July 9, 2013 under Local Codes T2 and T4.

USA v. SCHROEDER, et al 2:13-cr-00144 Stip and [Proposed] Order Excluding Time

Plaintiff does not oppose this request.

4. Plaintiff does not oppose this request.

5. The parties agree and stipulate, and request that the Court find the following:

a. The government has produced over 600 pages of discovery to date, which includes interview reports, business records, and surveillance logs. That discovery also includes one compact disc of voluminous records from eBay and paypal. The government is in the process of providing search warrants, which will be provided by the end of this week. The government has begun the process of preparing protective orders to disclose the wiretap evidence to defense counsel. Finally, the government has made available for inspection and copying additional physical evidence seized during the execution of the search warrants. The parties stipulate that the nature of the investigation, the number of defendants, and the length of the conspiracy support a complexity finding under Local Code T2.

b. Counsel for defendants desire additional time to review and copy discovery for this matter and to conduct additional investigation.

c. Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking ...


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