STIPULATION AND [PROPOSED] ORDER TO ADVANCE THE CHANGE OF PLEA HEARING

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

IT IS HEREBY STIPULATED between the parties through their respective counsel, Assistant United States Attorney MATTHEW YELOVICH and Chief Assistant Federal Defender LINDA C. ALLISON, attorney for MARCO LOPEZ-SANDOVAL, that the change of plea hearing set for May 20, 2016 be vacated and advanced to May 13, 2016 at 9:00 a.m.

The parties further stipulate and agree that the time from the date of this stipulation, May 3, 2016 through May 13, 2016 should be excluded from the time calculations under the Speedy Trial Act. 18 U.S.C. § 3161. There are several grounds to exclude time in this case. First, the defense needs additional time to review the plea agreement and meet with Mr. Lopez-Sandoval. The parties therefore stipulate that the ends of justice are served by the Court excluding such time, so that counsel for the defendant may have reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. §3161(h)(7)(A) and (B)(iv) [reasonable time to prepare] and Local Code T-4. In addition, the parties agree that time should be excluded pursuant to 18 U.S.C. §3161(h)(7)(B)(ii) and Local Code T2 since the District Court in M.D. La. made a finding back on August 13, 2015 that this case is complex.

For all of these reasons, the parties stipulate and agree to exclude time from the date of this stipulation May 3, 2016 to May 13, 2016 under the Speedy Trial Act (18 U.S.C. § 3161) and the Local Rules.

Respectfully submitted.

ORDER

IT IS HEREBY ORDERED that the change of plea hearing set for May 20, 2016 at 9:00 a.m. be vacated and advanced to May 13, 2016 at 9:00 a.m.

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 from the date of this order though May 13, 2016, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(1)(D), (h)(7)(A), (B)(iv) and Local Code T4 because it results from a continuance granted by the Court at both parties' 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.