STIPULATION TO CONTINUE; [PROPOSED] ORDER CONTINUING CASE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT

JON S. TIGAR, District Judge.

IT IS HEREBY STIPULATED, by and between the parties to this action, that the STATUS HEARING date of April 17, 2015 presently scheduled at 9:30 a.m., before the Honorable John S. Tigar, be vacated and re-set for April 24, 2015 at 9:30 a.m. for CHANGE OF PLEA.

The reason for this request is that the parties have reached a resolution of this case in principle, but additional time is needed to draft a proposed plea agreement and seek approval for it. The defense will also need time to review the plea agreement with Mr. Dieago. The parties agree and stipulate that the time until April 24, 2015 should be excluded, under 18 U.S.C. §3161(H)(7)(A) and (B)(iv), because the ends of justice served by the granting of the continuance outweigh the bests interests of the public and the defendant in a speedy and public trial. The continuance is necessary to accommodate both counsels' preparation efforts.

ORDER

The court finds that the ends of justice served by the granting of the continuance outweigh the bests interests of the public and the defendant in a speedy and public trial. The continuance is necessary to accommodate both counsels' preparation efforts including the drafting of the plea agreement, as well as review of document with the defendant. Based on these findings,

it is hereby ORDERED that the above-captioned matter be continued to April 24, 2015 at 9:30 a.m. for CHANGE OF PLEA, and that time be excluded from the date of this order to April 24, 2015 pursuant to 18 U.S.C. §§3161(h)(7)(A) and (B)(iv).

IT IS SO ORDERED.