STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

JOHN A. MENDEZ, District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jared Dolan, defendant, Jason Schroeder, by and through his counsel, Timothy Zindel, defendant, John Young, by and through his counsel, Philip Cozens, defendant, Kirk Sanderson, by and through his counsel, Clemente Jimenez, defendant, Jason Reed, by and through his counsel, Bruce Locke, defendant, David Reed, by and through his counsel, Erin J. Radekin, defendant, Maribel Martinez, by and through her counsel, Jesse Ortiz, defendant, Joshua Payne, by and through his counsel, Candice L. Fields, and defendant, Andrea Turner, by and through her counsel, Linda Parisi, agree and stipulate to vacate the date set for status conference, September 9, 2014 at 9:30 a.m., in the above-captioned matter, and to continue the status conference to September 30, 2014 at 9:30 a.m. in the courtroom of the Honorable John A. Mendez.

The reason for this request is that additional time is needed by the defense to review recently provided additional discovery, complete plea negotiations and other defense preparation. The Court is advised that all counsel above concur with this request and 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 September 30, 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 September 9, 2014 at 9:30 a.m. is VACATED and the above-captioned matter is set for status conference on September 30, 2014 at 9:30 a.m. The Court finds excludable time in this matter through September 30, 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.