STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME FROM AUGUST 4, 2017 TO OCTOBER 6, 2017

JON S. TIGAR, District Judge.

A status conference in this matter is currently set for August 4, 2017, at 9:30 a.m. The undersigned Assistant United States Attorney unexpectedly has to attend an out-of-state funeral on that date. In addition, the government recently obtained a Superseding Indictment in this matter (ECF 15) which adds a new defendant, John Manuel Dovala, and one new count as to Hatch: conspiracy to deal in firearms without a license, in violation of 18 U.S.C. § 371. The government will be producing to defense counsel a significant amount of additional discovery related to the conspiracy.

In light of the foregoing, the parties are in agreement that the August 4 status conference should be continued. Defense counsel will need additional time to evaluate the forthcoming discovery on the conspiracy count and may wish to coordinate, at least to some degree, with counsel for co-defendant Dovala. The parties anticipate that the case as to Hatch will resolve without a trial, and additional time will also allow for plea negotiations.

In terms of rescheduling, however, defense counsel Harris Taback's next available date is Friday, October 6, 2017, owing to scheduling conflicts in August and a planned sabbatical during the entire month of September. Accordingly, the parties hereby request and stipulate that the status conference be continued by approximately eight weeks, to Friday, October 6, 2017, and that the time between August 4, 2017, and October 6, 2017 be excluded for continuity of counsel and effective preparation of counsel, pursuant to 18 U.S.C. § 3161(h)(7)(B)(iv).

IT SO STIPULATED.

[PROPOSED] ORDER

Based on the parties' stipulation and for good cause shown, the August 4, 2017, status conference in the above-captioned matter is hereby continued to Friday, October 6, 2017, at 9:30 a.m. The time between August 4, 2017 and October 6, 2017 is excluded from the running of the speedy trial clock for continuity of counsel and effective preparation of counsel under 18 U.S.C. § 3161(h)(7)(B)(iv).

IT IS SO ORDERED.

Attestation of Filer

In addition to myself, the other signatory to this document is Harris B. Taback. I attest that I have his permission to enter a conformed signature on his behalf and to file the document.