STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING DATE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT

LUCY H. KOH, District Judge.

The defendant, Robert Rinehart, represented by Assistant Federal Public Defender Diana A. Garrido, and the government, represented by Assistant United States Attorney Jeffrey B. Schenk, hereby stipulate that, with the Court's approval, the status conference currently set for Wednesday, April 17, 2013 at 9:00 a.m., shall be continued to Wednesday, June 5, 2013 at 9:00 a.m.

The continuance is requested to provide both defense counsel and the government with additional time to review discovery and to negotiate an appropriate resolution. The continuance would provide both parties with the reasonable time necessary for effective preparation. Further, defense counsel is unavailable until June because she has been selected as an alternate juror in a six week trial commencing April 16, 2013 in San Francisco. Accordingly, both parties respectfully request that the time between April 17, 2013 and June 5, 2013 be excluded under the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).

[PROPOSED] ORDER

Pursuant to agreement and stipulation of the parties, the Court HEREBY ORDERS that the status conference set for April 17, 2013 be continued to June 5, 2013. The Court FURTHER ORDERS that the time between April 17, 2013 and June 5, 2013 is excluded under the Speedy Trial Act, 18 U.S.C. §3161. The Court finds, pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv), that the failure to grant the requested continuance would unreasonably deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Furthermore, the Court finds that the ends of justice served by granting the requested continuance outweigh the best interest of the public and the defendant in a speedy trial. The Court therefore concludes that this exclusion of time should be made under 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).

IT IS SO ORDERED.