STIPULATION AND [PROPOSED] ORDER CONTINUING CHANGE OF PLEA DATE; EXCLUSION OF TIME

JON S. TIGAR, District Judge.

STIPULATION

IT IS HEREBY STIPULATED, by and between the parties to this action, that the change of plea date for defendant Robert Doyle, currently scheduled for September 26, 2014, at 9:30 a.m., may be continued to December 12, 2014, at 9:30 a.m. for change of plea. The parties have met and conferred and agree that one additional continuance is needed prior to the change of plea to enable Mr. Doyle to obtain additional discovery from the government which he believes will provide mitigation for purposes of sentencing. The discovery relates to a search which was executed, prior to Mr. Doyle's initial appearance in this case, in which a number of Mr. Doyle's client files were taken. Mr. Doyle has requested, and the government has agreed to provide, this discovery but it will take time for the government to copy and provide the additional discovery and for Mr. Doyle to review this discovery. A continuance will enable the discovery to be provided and reviewed, and for the parties to finalize the terms of the plea agreement prior to the change of plea date.

IT IS FURTHER STIPULATED THAT the time to December 12, 2014, should be excluded in accordance with the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(1)(A) and (h)(7)(B)(iv) for effective preparation taking into consideration due diligence to enable counsel to obtain the additional discovery, meet with the government and finalize the terms of the plea agreement prior to the change of plea.

I hereby attest that I have permission of the parties to enter a conformed signature (/s/) for all signatures within this e-filed document.

ORDER

GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the change of plea date for defendant Robert Doyle, currently scheduled for September 26, 2014, at 9:30 a.m., may be continued to December 12, 2014, at 9:30 a.m. for change of plea.

IT IS FURTHER ORDERED THAT the time from September 26, 2014, to December 12, 2014, should be excluded in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(1)(A) and (h)(7)(B)(iv) for effective preparation of counsel taking into consideration due diligence to enable defense counsel to obtain the additional discovery, meet with the government and finalize the terms of the agreement prior to the change of plea date. The Court finds there is good cause and that the ends of justice served by the granting of the continuance outweigh the interests of the public and defendant in a speedy and public trial. Failure to grant the requested continuance would unreasonably deny counsel reasonable time necessary for effective preparation, taking into account due diligence.

SO ORDERED.