AMENDED STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

MORRISON C. ENGLAND, Jr., Chief District Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jill Thomas and defendant Antonia Reyna, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for status conference, September 18, 2014 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to November 6, 2014 at 9:00 a.m. in the courtroom of the Honorable Morrison C. England, Jr.

The reason for this request is as follows: The defense requested additional discovery from the government, and the government recently provided most of the requested items. The government declined to provide all items requested. Hence, the defense needs additional time to review the new discovery and evaluate whether to file a discovery motion. The defense is also conducting additional investigation and engaged in other defense preparation. The Court is advised that Ms. Thomas concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until November 6, 2014 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED.

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of September 18, 2014 at 9:00 a.m. is VACATED and the above-captioned matter is SET for status conference on November 6, 2014 at 9:00 a.m. The Court finds excludable time in this matter through November 6, 2014 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the ends of justice served by granting a continuance outweigh the best interests of the public and the Defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.