STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

GARLAND E. BURRELL, Jr., District Judge.

The United States of America, through its counsels of record, Benjamin B. Wagner, United States Attorney for the Eastern District of California, and Jill Thomas, Assistant United States Attorney, and defendant Abraham Valdez, through his attorney, Ronald Peters, Esq, hereby stipulate and agree that the status conference scheduled for March 25, 2016 at 9:00 am should be continued to April 22, 2016 at 9:00 a.m.

The government intends to provide the defendant with additional discovery which includes surveillance videos, that is, pole camera evidence. It will take time for the defense to review these videos. The defendant's attorney, the undersigned, has been involved in preparing for a three month jury trial which until recently was scheduled to commence on April 3, 2016 and has not had sufficient opportunity to review discovery with the defendant. The case remains complex in terms of dealing with discovery in cases involving other defendants not charged in this indictment but similarly situated.

Parties agree that time should be excluded pursuant to 18 U.S.C. § 3161(h)(8)(B)(iv), and Local Code T-4 — reasonable time to prepare and for continuity of counsel. The parties agree that time be excluded under this provision from March 25, 2016 to and including April 22, 2016.

PROPOSED ORDER

The Court, having considered the stipulation of the parties, and good cause appearing therefrom, adopts the stipulation of the parties in its entirety as its order. Based on the stipulation of the parties, the Court finds that 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, and defendant continuity of counsel. The Court specifically finds that the ends of justice served by the granting of such continuance outweigh the interests of the public and that the time from the date of the stipulation, March 25, 2016, to and including April 22, 2016.

It is so ordered.