STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT

GARLAND E. BURRELL, Jr., Senior District Judge.

Plaintiff United States of America by and through Assistant United States Attorney Justin Lee and Defendant Carl Woodruff by and through his attorney Todd D. Leras, request that the Court continue the status conference as to Defendant Woodruff to September 8, 2017.

This case involves an allegation of child abduction in which relevant actions occurred in the Eastern and Central Districts of California, the District of Nevada, the Eastern District of Virginia, as well as other locations. Co-Defendant Elena Gutierrez has resolved her case and is pending sentencing on August 25, 2017.

Defendant Woodruff's ongoing investigation of potential defenses is continuing and can fairly be characterized as nation-wide in scope. Defendant has provided the government with additional information to consider regarding potential resolution of this matter. Defendant Woodruff is requesting continuance of the status conference to complete his separate investigation of matters relevant to his defense. He is also requesting additional time to allow the government to continue evaluating the previously-provided information and to provide additional materials, if necessary, related to potential resolution of this matter. The government does not oppose the request for a continuance.

For the reasons stated in the preceding paragraph, Defendant Carl Woodruff requests continuance of his status conference to September 8, 2017. He also stipulates and agrees to an exclusion of time for the period from August 11, 2017, up to and including September 8, 2017, based on the need for reasonable preparation time. Assistant U.S. Attorney Justin Lee has reviewed this stipulation and proposed order and authorized Todd D. Leras to sign it on his behalf.

ORDER

BASED ON THE REPRESENTATIONS AND STIPULATION OF THE UNITED STATES AND DEFENDANT CARL WOODRUFF, it is hereby ordered that the status conference scheduled for August 11, 2017 is vacated. A new status conference is scheduled for Defendant Woodruff on September 8, 2017, at 9:00 a.m. The Court further finds, based on the representations of the United States and Defendant Woodruff, that the ends of justice served by granting the continuance outweigh the best interests of the public and the Defendant in a speedy trial. Time shall be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(4) and Local Code T-4, to allow necessary attorney preparation taking into consideration the exercise of due diligence for the period from August 11, 2017, up to and including September 8, 2017.