STIPULATION AND ORDER TO VACATE CURRENT TRIAL DATE AND SETTING NEW TRIAL DATE (note new date)

LAWRENCE J. O'NEILL, Chief District Judge.

TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE LAWRENCE J. O'NEILL AND BRIAN K. DELANEY, ASSISTANT UNITED STATES ATTORNEY:

COMES NOW Defendant, ROBIN LEE by and through her attorney of record, Virna L. Santos, hereby requesting that Court vacate the trial date currently set for April 11, 2017 and set a new trial date of August 29, 2017.

This continuance is necessary to permit additional investigation of a matter required for Ms. Lee's defense and/or resolution via plea bargain. This issue was identified recently and the court approved expert funds for its investigation on February 14, 2017. While the parties anticipate a negotiated resolution of the case against Ms. Lee, it is necessary to exhaust this avenue of investigation before the undersigned may fully advise her of all available defenses.

AUSA Brian K. Delaney has no objection to the request and agrees to the new proposed trial date.

The parties also agree that the delays resulting from the continuance shall be excluded in the interest of justice pursuant to 18 USC 3161 (h)(7)(A) and 3161 (h)(7)(B)(1).

IS SO STIPULATED.

ORDER

The trial date currently set for April 11, 2017 is hereby VACATED. A new trial date of September 26, 2017 at 8:30 a.m. is hereby set. (the August date is not available on calendar). Time is excluded for defense investigation, consideration of a plea agreement and in the interest of justice pursuant to 18 USC 3161 (h)(7)(A) and 3161 (h)(7)(B)(1).

IT IS SO ORDERED.