STIPULATION AND ORDER VACATING DATE, CONTINUING STATUS CONFERENCE AND EXCLUDING TIME; [PROPOSED] FINDINGS AND ORDER

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

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendant, by and through his counsel of record, hereby stipulate that the status conference scheduled for October 16, 2015 at 9:00 a.m. should be vacated and the matter continued to this Corut's criminal calendar on November 13, 2015, for further status conference.

By this stipulation, defendant now moves to continue the status conference until November 13, 2015 and to exclude time between July 31, 2015 and November 13, 2015 under Local Code T4. The government does not object to the continuance.

3. The parties agree and stipulate, and request that the Court find the following:

a. The parties are in active plea negotiations, and defense counsel desires additional time to consult with his client, review the current charges and discovery, and discuss potential resolutions with his client, including proposed plea agreements and counter-offer(s).

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny him/her the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act. 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 of July 31, 2015 to November 13, 2013, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendant's 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.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

IT IS SO STIPULATED.

ORDER

IT IS SO FOUND AND ORDERED.