STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

TROY L. NUNLEY, District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant Sarah N. Nattress, by and through her counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on October 16, 2014.

2. By this stipulation, defendant now moves to continue the status conference until October 23, 2014, and to exclude time between October 16, 2014 and October 23, 2014, under Local Code T4. Plaintiff does not oppose this request.

3. The parties agree and stipulate, and request that the Court find the following:

a. This matter was arraigned on May 30, 2014. Counsel for defendant is still awaiting initial discovery. The government has indicated that it will be provided shortly.

b. Counsel for defendant desires additional time to complete the review of discovery, to conduct defense investigation, and to discuss potential resolutions with her client. Counsel is continuing to engage in negotiations with the government. Counsel and the government have made significant headway on negotiations and expect the case to resolve on October 23, 2014.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny her the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

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

f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of October 16, 2014 to October 23, 2014, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendant's 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 defendant 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.

ORDER

IT IS SO FOUND AND ORDERED.