STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

GARLAND E. BURRELL, Jr., Senior District Judge.

The defendants, Scott Albert Johnson, Donald Loyde Harned, Daniel Allen Coats, Joseph Robert Sharp and Edwin Forrest Ludwig, III, by and through their undersigned counsel, and the United States, by and through its undersigned counsel, hereby agree and request the status conference currently set for Friday, February 19, 2016 at 9:00 am be vacated and continued to Friday, March 18, 2016 at 9:00 am.

This continuance is necessary as the parties are at various stages in plea negotiations and require additional time to review discovery, investigate the facts of this case, and hold discussions with the government and their respective client's in furtherance of resolution. Counsel for the government is working to produce and revise plea offers; counsel for Mr. Sharpe is in the process of obtaining documents relating to a medical diagnosis, and also looking into an appeal now pending in state court, both of which are likely to affect resolution; counsel for Messrs. Coats and Johnson have requested modifications to their plea agreements and counsel for Mr. Johnson is involved in a murder trial, which is not expected to conclude until the first week of March; counsel for Harned is reviewing a proposed plea offer and needs further time to investigate and to meet with his client who is on pretrial release in Oklahoma City; and Ludwig III is awaiting a proposed plea agreement from Assistant U.S. Attorney Haus and will likely be involved in a preliminary hearing in superior court.

The parties stipulate that the Court shall find and order: (1) the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence; (2) the ends of justice to be served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial; and (3) time beginning from the parties' stipulation on February 17, 2016, up to and including the March 18, 2016, status conference shall be excluded from the computation of time within which the trial of this matter must be commenced under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T-4, to allow defense counsel reasonable time to prepare.

I, William E. Bonham, the filing party, have received authorization from AUSA Sherry Haus and remaining defense counsel to sign and submit this stipulation and proposed order on their behalf.

ORDER

IT IS ORDERED that the status conference currently set for Friday, February 19, 2016 at 9:00 am is vacated and continued to Friday, March 18, 2016 at 9:00 a.m. Based on the stipulation of the parties, I find that the failure to grant such a continuance would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Accordingly, the time within which the trial of this case must be commenced under the Speedy Trial Act is excluded from the date of the parties' stipulation, February 17, 2016, up to and including the date of the new status conference, March 18, 2016, pursuant to Local Code T4 and 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). I specifically find that the ends of justice served by granting this continuance outweigh the best interest of the public and defendants in a speedy trial within the meaning of 18 U.S.C. § 3161(h) (7)(A) and (B)(iv) and Local Code T-4.