Opinion
SCOTT N. CAMERON, Attorney at Law, Sacramento, CA, BENJAMIN B. WAGNER, United States Attorney, Michael Beckwith, Assistant United States Attorney, Attorney for MARCUS BUCKLEY.
AMENDED STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; FINDINGS AND ORDER
TROY L. NUNLEY, District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, AUSA Michael Beckwith, and defendant MARCUS BUCKLEY, by and through his counsel of record, Scott N. Cameron, hereby stipulate as follows:
1. By previous order, this matter was set for a status conference on October 1, 2015, at 9:30 a.m.
2. By this stipulation, defendant now move to continue the status conference to December 10, 2015, at 9:30 a.m., and to exclude time between October 1, 2015, and December 10, 2015, 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 produced discovery to the defense in this case which consists of over 8, 000 pages of documents.
b. Defense counsel requires additional time to review discovery with his client and conduct investigation. Thus defense counsel is requesting the additional time for counsel preparation.
c. The government does not object to the continuance.
d. 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 defendants in a trial within the original date prescribed by the Speedy Trial Act.
e. 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 October 1, 2015, to December 10, 2015, 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 defendant's 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. (This Space Intentionally Left Blank)
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 the period within which a trial must commence.
IT IS SO STIPULATED.
ORDER.