STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME FROM OTHERWISE APPLICABLE SPEEDY TRIAL ACT CALCULATION

CHARLES R. BREYER, District Judge.

STIPULATION

IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that:

1. The parties are currently scheduled for a status hearing on November 18, 2015 at 12:00 p.m.

2. The parties have engaged in settlement discussions. However, more time would be beneficial and thus the parties respectfully request a short continuance of this case.

3. The parties now formalize their request for a continuance of this matter to December 9, 2015 at 2:00 p.m. for a further status conference, and respectfully submit and agree that the period from November 18, 2015 through and including December 9, 2015 should be excluded from the otherwise applicable Speedy Trial Act computation because the continuance is necessary for effective preparation of counsel, taking into account the exercise of due diligence. Specifically, the time requested for exclusion will allow defense counsel to review the forthcoming draft plea agreement with the defendant.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Based upon the above-described Stipulation, THE COURT FINDS THAT the ends of justice served by granting a continuance from November 18, 2015 through and including December 9, 2015 outweigh the best interest of the public and the defendant in a speedy trial, and that failure to grant such a continuance would unreasonably deny the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

Accordingly, THE COURT ORDERS THAT:

1. The parties shall appear before the Court on December 16, 2015 at 12:00 p.m. for a status hearing.

2. The period from November 18, 2015 through and including December 16, 2015 is excluded from the otherwise applicable Speedy Trial Act computation, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(iv).

IT IS SO ORDERED.