STIPULATION AND [PROPOSED] ORDER CONTINUING CASE AND EXCLUDING TIME

GARLAND E. BURRELL, Jr., District Judge.

IT IS HEREBY stipulated between the United States of America through its undersigned counsel, Samuel Wong, Assistant United States Attorney, attorney for plaintiff, together with Adam Koppekin, attorney for defendant Carlos Olazabal and Kyle Knapp, attorney for defendant Miguel Felix-Lopez that the previously-scheduled status conference, currently set for March 20, 2015, be vacated and that the matter be set for status conference on May 15, 2015 at 9:00 a.m.

Counsel have conferred and this continuance is requested to allow defense counsel additional time to finalize review of the discovery, meet again with our clients, investigate possible defenses and to continue exploring the relevant sentencing guidelines that would apply to our respective clients. In addition, the parameters of a plea agreement are being discussed with our respective clients and additional time is needed to finalize negotiations.

IT IS FURTHER STIPULATED that the ends of justice served by the granting of such a continuance outweigh the best interests of the public and the defendants in a speedy trial and that time within which the trial of this case must be commenced under the Speedy Trial Act shall therefore be excluded under 18 U.S.C. Section 3161(h)(7) (A) and (B) (iv), corresponding to Local Code T-4 (to allow defense counsel reasonable time to prepare) from the date of the parties' stipulation, March 13, 2015 up to and including May 15, 2015.

IT IS SO STIPULATED.

[PROPOSED] ORDER

The Stipulation of the parties in its entirety is hereby accepted and adopted as the Court's Order. The requested continuance is GRANTED. This matter shall be dropped from this court's March 20, 2015 criminal calendar and re-calendared for status conference on May 15, 2015.

Based on the representations of the parties the court finds that: (1) the failure to grant such a continuance in this case would deny counsel for defendants the reasonable time necessary for effective preparation, taking into account the exercise of due diligence; and (2) the ends of justice served by granting this continuance outweigh the best interests of the public and the defendants in a speedy trial. The Court orders that the time period from the filing of the parties' stipulation on March 13, 2015, through and including the May 15, 2015, status conference shall be excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. Section 3161(h)(7) (A) and (B) (iv), corresponding to Local Code T-4 (to allow defense counsel reasonable time to prepare).

IT IS SO ORDERED.