STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

MORRISON C. ENGLAND, Jr., Chief District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Michele M. Beckwith, defendant, Edwin Malo-Vergara, by and through his counsel, David W. Bonilla, defendant, Jose Junez-Ramirez, Sr., by and through his counsel, Kyle R. Knapp, and defendant, Ruben Aurelio Bulgin, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, May 8, 2014 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to June 19, 2014 at 9:00 a.m. in the courtroom of the Honorable Morrison C. England, Jr.

The reason for this request is that the defense needs additional time to complete investigation, other defense preparation, and plea negotiations. The defense is making arrangements for a Spanish interpreter to translate the wire recordings in this case, which are all in Spanish, in to English. The Court is advised that Ms. Beckwith concurs with this request and all counsel set forth above have authorized Ms. Radekin to sign this stipulation on their behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until June 19, 2014 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of May 15, 2014 at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on June 19, 2014 at 9:00 a.m. The Court finds excludable time in this matter through June 19, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.