STIPULATION AND ORDER CONTINUING TRIAL DATE

ANTHONY W. ISHII, Senior District Judge.

Plaintiff the United States of America ("government") and defendants ELISEO JARA, Jr., SERGIO JARA, LUCIA YOLANDA CHAVEZ, ARLENE JEANETTE MOJARDIN, JOSEPH SHAWN CHAVEZ, Jr., and MELISSA ROCHELLE JARA, by and through their respective undersigned counsel of record, hereby stipulate and jointly request that the trial date in this case be continued from February 10, 2015 to April 28, 2015, at 8:30 a.m., or the earliest available date thereafter. The parties further stipulate and jointly request that the trial confirmation hearing be reset from January 20, 2015 to April 6, 2015 at 10:00 a.m. The grounds for this stipulation are that, for the reasons set forth below, a continuance of the trial date to April 28, 2015 is required to provide additional time for effective defense preparation, plea negotiations, and further consideration of plea offers by the defendants, taking into account the exercise of due diligence, and to ensure continuity of defense counsel.

Defendants are currently in plea negotiations with the government and believe that it is in both the defendants' interests and in the interests of justice, and substantially more efficient for the parties and the Court, to provide this additional time to continue to narrow the potential defendants and issues for trial and to resolve the case. Given the voluminous discovery, the requested continuance is also required for effective defense preparation in the event that the ongoing plea negotiations do not resolve the case. If the requested continuance of the trial date were not granted, there would not be sufficient time for effective defense preparation and plea negotiations, notwithstanding counsel's exercise of due diligence.

The parties agree and stipulate that time should be excluded in the interests of justice from the current trial date on February 10, 2015 through and including the continued trial date under 18 U.S.C. § 3161(h)(7)(A) and (7)(B)(i) & (iv), in that the ends of justice served by the continuance outweigh the interests of the public and the defendants in a speedy trial.

IT IS SO STIPULATED.

ORDER

The Court has reviewed and considered the stipulation of the parties to continue the trial date and trial confirmation hearing in this case. Good cause appearing, IT IS ORDERED that the trial date in this case is continued to April 28, 2015, at 8:30 a.m., and that the trial confirmation hearing is continued to April 6, 2015 at 10:00 a.m. It is further ordered that time is excluded in the interests of justice from the current trial date on February 10, 2015 through and including the continued trial date on April 28, 2015 under 18 U.S.C. § 3161(h)(7)(A) and (7)(B)(i) & (iv), in that the ends of justice served by the continuance outweigh the interests of the public and the defendants in a speedy trial.

IT IS SO ORDERED.