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

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

The parties to this action, Plaintiff United States of America by and through Assistant United States Attorney Justin Lee, Defendant Elena Gutierrez by and through her attorney Tasha Chalfant, and Defendant Carl Woodruff by and through his attorney Todd D. Leras, request that the Court continue the status conference in this matter to March 18, 2016, at 9:00 a.m.

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. Chief Judge Morrison C. England, Jr., recently signed an order transferring this matter to this Court. Defense counsel are engaged in continuing investigation of matters at multiple locations across the nation. Counsel for Defendant Elena Gutierrez recently provided the government with significant information developed as a result of the investigation. The parties believe that exchange of relevant information may result in a negotiated resolution of the matter.

The parties have previously agreed by stipulation to exclude time under the Speedy Trial Act to January 21, 2016. For the reasons stated in the preceding paragraph, the parties are requesting to continue the status conference to March 18, 2016. They also stipulate and agree to an exclusion of time for the period from January 21, 2016, up to and including March 18, 2016. The parties further stipulate that this exclusion is appropriate based on the need for reasonable preparation time. All counsel have reviewed this proposed order and authorized Todd D. Leras to sign it on their behalf.

ORDER

BASED ON THE REPRESENTATIONS AND STIPULATION OF THE PARTIES, it is hereby ordered that the status conference in this matter scheduled for January 22, 2016, is vacated. A new status conference is scheduled for March 18, 2016, at 9:00 a.m. The Court further finds, based on the representations of the parties, that the ends of justice served by granting the continuance outweigh the best interests of the public and the Defendants 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 January 21, 2016, up to and including March 18, 2016.