STIPULATION AND PROPOSED ORDER TO CONTINUE THE STATUS CONFERENCE TO THURSDAY JULY 31, 2014

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

The parties to this litigation, the United States of America, represented by Assistant United States Attorney, Paul A. Hemesath, and for the defendants: Michael B. Bigelow, representing Jusstanene King and James R. Greiner, representing Charles Alexander, hereby agree and stipulate to the following1:

a. The government has produced discovery which consists of reports and statements and investigation by the government;

b. Counsel for all defendants need additional time to review all of the discovery in light of the new proposed Advisory Sentencing Guidelines which may take effect later on this calendar year, review all the discovery with their respective clients as well as discuss the new proposed Advisory Sentencing Guidelines which may take effect later on this calendar year, to conduct investigation into this case in light of the possible new Advisory Sentencing Guidelines, do legal research into the potential ramifications of the new proposed Advisory Sentencing Guidelines, which includes legal research, in this case, and to otherwise do review and investigation, using due diligence, that this case requires;

c. Counsel for all defendants represent that the failure to grant the above requested continuance would deny counsel for each individual defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government and the defense will also continue its discussions in resolving this case short of trial which will require the government to produce to the defense a proposed written plea agreement which defense counsel will need additional time to review, review with their respective clients, and to review in light of both the now existing Advisory Sentencing Guidelines and the potential new Advisory Sentencing Guidelines.

e. The government, based on all of the above, does not object to the continuance.

f. Based on the above stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and all the defendants in a trial within the original date prescribed by the Speedy Trial Act.

g. For the purpose of computing the time under the Speedy Trial Act, Title 18 U.S.C. section 3161, et seq., within which trial must commence, the time period from Thursday, May 1, 2014 to Thursday, July 31, 2014, inclusive, is deemed excludable pursuant to Title 18 U.S.C. section 3161(h)(7)(A) and (h)(7)(b)(iv), and (iv) corresponding to local code T-4, because it results from a continuance granted by the Court at defendants' request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendants in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

IT IS SO STIPULATED.

Each attorney has granted James R. Greiner full authority to sign for each individual attorney.

ORDER

IT IS SO FOUND AND ORDERED.