STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

WILLIAM B. SHUBB, District Judge.

It is hereby stipulated between the parties, Jason Hitt, Assistant United States Attorney, Michael D. Long, attorney for defendant Darren Betz, that the status conference date of November 24, 2014, should be continued until January 12, 2015. The continuance is necessary because Mr. Long and Mr. Hitt are still negotiating a plea disposition and have not finalized the terms as of yet. We anticipate resolving soon. Time has previously been excluded up until November 24 2014, and the parties continue to jointly agree that time should continue to be excluded until January 12, 2015. Each party further stipulates that the ends of justice served by granting such continuance outweigh the best interests of the public and of all the defendants in a speedy trial. Each party would like time to be excluded as provided by Local Code T4 from today's date through January 12, 2015.

IT IS STIPULATED that the period of time from the signing of this Order up to and including the new court date of January 12, 2015, be excluded in computing the time within which trial must commence under the Speedy Trial Act, pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, for ongoing preparation of counsel.

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for November 24, 2014, at 9:30 a.m. be continued to January 12, 2015, at 9:30 a.m. Based on the representations of counsel and good cause appearing therefrom, the Court hereby finds that the failure to grant a continuance in this case, based on the parties still negotiating the terms of a proposed plea agreement, would deny defense counsel reasonable time necessary for effective preparation, taking into account due diligence. The court finds that the reasons for granting this continuance outweigh the best interests of the public and the defendants to a speedy trial. It is ordered that time from this date to January 12, 2015, shall continue to be excluded from computation of the time within which the trial of this matter must be commenced under the Speedy Trial Act pursuant to 18 U.S.C. § 3161(h)(7) and Local Code T4, to allow counsel time to prepare and to complete negotiations.