BENJAMIN B. WAGNER, United States Attorney, TODD A. PICKLES, Assistant United States Attorney, Sacramento, CA, Attorneys for Plaintiff, United States of America.
DANIEL KOUKOL, ESQ., Counsel for Defendant.
STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; [PROPOSED] FINDINGS AND ORDER
GARLAND E. BURRELL, Jr., Senior District Judge.
Plaintiff United States of America, by and through its counsel of record, and defendant Tina Marie Bini, by and through her counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on December 20, 2013.
2. By this stipulation, defendant now moves to continue the status conference until January 24, 2014 and to exclude time between December 20, 2013 and January 24, 2014 under Local Code T4. The United States does not oppose this request.
3. The parties agree and stipulate, and request that the Court find the following:
a) The United States has represented that the discovery associated with this case includes investigative reports and wiretap applications in electronic form constituting approximately 800 pages of documents. All of this discovery has been produced directly to counsel.
b) Further, the United States anticipates making a further production of documents and audio recordings, including intercepted communications, within the next few weeks which are anticipated to be voluminous.
c) Counsel for defendant desires additional time to consult with his client, to conduct investigation and research related to the charges, to review discovery for this matter, to discuss potential resolutions with his client, and to otherwise prepare for trial.
d) Counsel for defendant believes that failure to grant the above-requested continuance would deny him the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.
e) The United States does not object to the continuance.
f) 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 ...