United States District Court, E.D. California
Bruce Locke, Moss & Locke, Sacramento, CA, Attorney.
STIPULATION AND ORDER
MORRISON C. ENGLAND, Jr., Chief District Judge.
1. By previous order, this matter was set for status on February 27, 2014.
2. By this stipulation, defendants now move to continue the status conference until June 19, 2014, and to exclude time between February 27, 2014 and June 19, 2014, under Local Code T4.
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 700 pages. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.
b) Counsel for defendants desire additional time to review the discovery, conduct investigation, consider resolution of the case without trial, and/or prepare for trial.
c) Counsel for defendants believe that failure to grant the above-requested continuance would deny counsel 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 original date prescribed by the Speedy Trial Act.
f) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of February 27, 2014 to June 19, 2014, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendants' request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from ...