MELINDA HAAG (CABN 132612), United States Attorney, J. DOUGLAS WILSON (DCBN 412811), Chief, Criminal Division, CAROLYN SILANE (NYBN 4596235), Special Assistant United States Attorney, San Francisco, California, Attorneys for the United States of America.
STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME UNDER 18 U.S.C. § 3161
MAXINE M. CHESNEY, District Judge.
The parties in this case were scheduled to appear before the Court on July 10, 2013. Due to scheduling conflicts, the Court sought to reschedule the appearance. The parties request that the matter be set to August 28, 2013, and agree to exclude the periods of time from July 10, 2013 to August 28, 2013, from any time limits applicable under 18 U.S.C. § 3161. The government has produced substantial discovery to date, and the parties agree that granting the exclusion would allow the reasonable time necessary for effective preparation of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such an exclusion of time outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A). SO STIPULATED:
For the reasons stated above, the Court finds that the exclusion from the time limits applicable under 18 U.S.C. § 3161 is warranted and that the ends of justice served by the continuance outweigh the best interests of the public and the defendant in a speedy trial for the periods from July 10, 2013 to August 28, 2013. 18 U.S.C. § 3161(h)(7)(A). Denying the requested exclusion of time would deprive the parties of the reasonable time ...