STIPULATION AND [PROPOSED] ORDER CONTINUING TRIAL DATE AND PRE-TRIAL CONFERENCE AND DUE DATE FOR FILING OF STATUS REPORT SAN FRANCISCO VENUE

JOHN S. TIGAR, Magistrate Judge.

The trial in this case is currently scheduled to begin May 12, 2014, with the pre-trial conference scheduled to begin on May 7, 2014, and the status report is scheduled to be filed by April 23, 2014However, another client represented by undersigned defense counsel invoked his right to speedy trial and received a trial date of May 7, 2014 (Case No. 12-CR-0505-MMC). The defense is therefore requesting that the trial date be rescheduled for July 7, 2014, and the pre-trial conference be rescheduled for June 27, 2014, and the status report be filed on June 13, 2014. Counsel for the Government, Assistant United States Attorney Katie Medearis does not oppose the defense request to reset the trial date and agrees to the proposed new trial date.

The parties further request that time be excluded from May 7, 2014 until July 7, 2014 to allow for effective preparation of counsel.

IT IS SO STIPULATED

[PROPOSED] ORDER

For good cause shown, the pre-trial conference and trial dates are vacated. The due date for the filing of the status report is vacated. The pre-trial conference is re-scheduled for June 27, 2014 at 9:00 A.M., and the trial is rescheduled for July 7, 2014 at 9:00 A.M. The status report is to be filed by June 13, 2014.

IT IS FURTHER ORDERED that based on the reasons stated by defense counsel, it is further ordered that time between May 7, 2014 and July 7, 2014 is excluded under the Speedy Trial Act, 18 U.S.C. § 3161(b), and that failure to grant the continuance of the trial date would unreasonably deny the defendant the time necessary for effective preparation of counsel and allow for continuity of counsel, taking into account the exercise of due diligence.

IT IS SO ORDERED.