STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

RICHARD SEEBORG, District Judge.

Defendant Gregg Jaclin, by and through his counsel, Edward W. Swanson, and the United States, by and through Assistant United States Attorney Benjamin Kingsley, hereby stipulate and agree as follows:

1) The above-captioned case is scheduled for a status conference on July 17, 2018 at 2:30 p.m.

2) Mr. Jaclin's father-in-law passed away on June 24, 2018. Mr. Jaclin and his wife require time to make funeral and estate arrangements as well as to grieve. The parties therefore stipulate to continue the hearing by three weeks to August 7, 2018 at 2:30 p.m., or as soon thereafter as the Court is available.

3) The parties also stipulate and request that the Court exclude from the time limits of 18 U.S.C. § 3161 the period from July 17, 2018 through August 7, 2018. The parties stipulate that the continuance should be granted in order to allow adequate time for defense preparation pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv), as defense counsel continue to review the voluminous discovery in this case and conduct their own investigation. The parties further stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §3161(h)(7)(A).

4) Therefore, the parties HEREBY STIPULATE that the status conference set for July 17, 2018 at 2:30 p.m. be continued to August 7, 2018 at 2:30 p.m., and that time be excluded from the time limits of 18 U.S.C. § 3161 for the period from July 17, 2018 through August 7, 2018.

IT IS SO STIPULATED.

ORDER

For the reasons stated above, the Court HEREBY CONTINUES the status conference currently set for July 17, 2018 at 2:30 p.m. until August 7, 2018 at 2:30 p.m., and that exclusion of time between July 17, 2018 and August 7, 2018 is warranted under 18 U.S.C. § 3161; that the ends of justice served by the continuance outweigh the interests of the public and the defendant in the prompt disposition of this criminal case; and that the failure to grant the requested exclusion of time would deny counsel for the defendant and for the government the reasonable time necessary for effective preparation of counsel, taking into account the exercise of due diligence, and would result in a miscarriage of justice. 18 U.S.C. § 3161(h)(7)(B)(iv).