STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

MORRISON C. ENGLAND, Jr., Chief District Judge.

The defendant, KAYODE GEORGE GANSAH, by and through his undersigned counsel and the United States by and through its undersigned counsel, hereby stipulate and request that the status conference currently set for Thursday, September10, 2015 at 9:00 am be vacated and reset for Thursday, September 24, 2015 at 9:00 am.

A continuance is necessary to allow defense counsel more time to complete defense investigation of new discovery provided by the government, including setting appointment with the government for evidence review(appointment now set for Friday, September 18, 2015 in Oakland, CA with case agent and defense investigator & attorney), evaluate the case, to have additional discussions with his client and negotiations with the government toward a potential resolution of the charges.

The parties further stipulate that the failure to grant a continuance in this matter would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence; that the ends of justice served by granting this continuance outweigh the best interest of the public and the defendant in a speedy trial; and that time should be excluded from the computation of time within which trial must commence under the Speedy Trial Act from September 10, 2015, up to and including September 24, 2015, pursuant to 18 U.S.C. § 3161 (h)(7)(A) and (B)(iv) and Local Code T-4, to allow defense counsel reasonable time to prepare.

I, William E. Bonham, the filing party, have received authorization from AUSA Jason Hitt to sign and submit this stipulation and proposed order on his behalf.

Accordingly, the defense and the United States agree and stipulate that the status conference for defendant Kayode George Gansah should be reset for Thursday, September 24, 2015 at 9:00 am before the Honorable Morrison C. England, Jr.

ORDER

The status conference currently set for Thursday, September 10, 2015 at 9:00 am is vacated and reset for Thursday, September 24, 2015, at 9:00 am. The Court finds that the failure to grant such a continuance would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Accordingly, the time within which the trial of this case must be commenced under the Speedy Trial Act is excluded from September 10, 2015, up to and including the date of the new status conference, September 24, 2015, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T4. The Court specifically finds that the ends of justice served by granting this continuance outweigh the best interest of the public and defendants in a speedy trial within the meaning of 18 U.S.C. § 3161(h) (7) (A) and (B) (IV) and Local Code T-4.

IT IS SO ORDERED.