STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE

DALE A. DROZD, Magistrate Judge.

It is hereby stipulated between the parties, Olusere Olowoyeye, Assistant United States Attorney, and Michael D. Long, attorney for defendant CAMERON LARSEN, that the preliminary hearing set for August 21, 2014, at 2:00 p.m. should be vacated and re-set for October 7, 2014, at 2:00 p.m.

The parties further agree, pursuant to Fed.R.Crim.Pro. 5.1(c) and (d), that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown.

In mid-December of 2013 the Larsen family suffered through the tragic death of Cameron Larsen's father, Dr. Larsen. Defense counsel and the government believe it is appropriate to delay proceeding to preliminary hearing or indictment to allow Cameron Larsen and his family to deal with the tragedy, including the emotional and financial consequences of the tragedy. Cameron Larsen is still attending counseling. Mr. Larsen has found new full-time employment and also continues to work on the family farm.

Defense counsel has met with Mr. Larsen many times, and will continue to meet with Mr. Larsen in the near future, to review the discovery provided by the government. Additionally, defense counsel and the government have engaged in, and will continue to engage in, negotiations with the goal of settling this matter before the filing of an indictment.

Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy filing of an indictment and also outweighs the public's interest in the prompt disposition of criminal cases. Each party would like time to be excluded as provided by Local Code T4 from today's date through October 7, 2014, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv).

All parties request the date of October 7, 2014, for the preliminary hearing. The request for extending the date for the status conference is at the specific request of the defendant and with the knowing, intelligent and voluntary waiver of his speedy preliminary hearing rights under the law. The parties believe that good cause is hereby shown.

Dated: August 4, 2014. Respectfully submitted,

ORDER

GOOD CAUSE APPEARING AND HAVING BEEN SHOWN, IT IS SO ORDERED.

The date for the preliminary hearing in this matter is hereby re-set for October 7, 2014, at 2:00 p.m., before Magistrate Court Judge Carolyn K. Delaney.