STIPULATION AND ORDER FOR CONTINUANCE OF CHANGE OF PLEA HEARING

DALE A. DROZD, District Judge.

Defendant, LAIMIRO BOBADILLA, through his attorney ROBERT L. FORKNER, together with the United States of America through its undersigned counsel, VINCENZA RABENN, Assistant United States Attorney, hereby stipulate and request the following:

1. That the Court continue the change of plea hearing in the above-captioned case from June 24, 2019, to July 15, 2019, at 9:30 a.m.

2. Due to a conflict in Mr. Forkner's calendar, defense counsel was unable to meet with Mr. BOBADILLA prior to the current scheduled hearing of June 24, 2019, Mr. Forkner was dealing with a loss of a family member. Ms. Echevarria was in a Jury Trial in Stanislaus County Case number 4020070. Further, defendant's work schedule did not allow for sufficient time to meet with Mr. Bobadilla; in order to answer his questions, research, and file possible defense motions.

3. A continuance is requested to allow defense counsel time to file any motions before the currently scheduled date. The government and probation officer have been notified and have no objections.

For these reasons, the parties stipulate and request that the Court exclude time which the trial must commence under the Speedy Trial Act from June 24, 2019 through July 15, 2019, for defense preparation under 18 U.S.C. § 3161(h)(8)(B)(ii) and (iv).

IT IS SO STIPULATED.

ORDER TO CONTINUE SENTENCING HEARING

Pursuant to the stipulation of the parties, defendant's Change of Plea Hearing in the above-entitled case shall be continued from June 24, 2019 to July 15, 2019 at 10:00 a.m. and the time which the trial must commence is excluded under the Speedy Trial Act from June 24, 2019 through July 15, 2019, for defense preparation under 18 U.S.C. § 3161(h)(8)(B)(ii) and (iv)

IT IS SO ORDERED.