STIPULATION AND [PROPOSED] ORDER TO EXCLUDE TIME

WILLIAM B. SHUBB, District Judge.

The parties hereby stipulate that the status conference in this case be continued from Monday, March 24, 2014, at 9:30 a.m. to Monday, May 5, 2014, at 9:30 a.m. The parties stipulate that the time between March 24, 2014, and May 5, 2014, should be excluded from the calculation of time under the Speedy Trial Act. The parties stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T-4. Moreover, the parties continue to engage in discussions about a possible resolution that could benefit the defendant by significantly reducing his possible sentencing exposure in this case. For these reasons, the defendant agrees that a continuance. Therefore the parties have stipulated to continue the status conference in this case. The parties stipulate and agree that the interests of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161 (h)(7)(A).

The parties further request that this matter be taken off the March 24, 2014, calendar before Judge William B. Shubb and be rescheduled for May 5, 2014, at 9:30 a.m. before Judge Shubb.

ORDER

IT IS HEREBY ORDERED that the Status Conference in the above-entitled matter is continued to May 5, 2014, at 9:30 a.m. before the Honorable William B. Shubb and that the time between March 24, 2014, and May 5, 2014, be excluded from the calculation of time under the Speedy Trial Act.