STIPULATION AND [PROPOSED] ORDER TO STATUS CONFERENCE

ALLISON CLAIRE, Magistrate Judge.

It is hereby stipulated between the parties, Olusere Olowoyeye, Assistant United States Attorney, and Michael D. Long, attorney for defendant CAMERON LARSEN, that (1) a change of plea hearing set for December 12, 2014, at 2:00 p.m. before Judge Carolyn K. Delaney and (2) the preliminary hearing currently set for December 2, 2014, at 2:00 p.m. should be vacated and re-set for December 19, 2014, at 2:00 p.m., before Judge Alison Claire.

The parties further agree, pursuant to Fed.R.Crim.Pro. 5.1(c) and (d), that this court should make a finding of good cause for the requested extension and that in fact good cause is hereby shown.

The continuance from December 2 to December 12, 2014, is necessary because Mr. Long is in trial before Judge Robert Twiss of the Sacramento County Superior Court. The Government has recently provided a proposed plea agreement that Mr. Long needs to review with Mr. Larsen.

Mr. Larsen has found full-time employment as a welder and also continues to work on the family farm.

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 filing of an indictment and also outweighs the public's interest in the prompt disposition of criminal cases. Each party would like time to be excluded as provided by Local Code T4 from today's date through December 19, 2014, for the effective preparation of all counsel, taking in to account due diligence. 18 U.S.C. section 3161(b)(7)(B)(iv).

All parties request the date of December 12, 2014, for a change of plea hearing and, in case a guilty plea is not entered, a preliminary hearing date set for December 19, 2014. The request for extending the date for the status conference is at the specific request of the defendant and with the knowing, intelligent and voluntary waiver of his speedy preliminary hearing rights under the law. The parties believe that good cause is hereby shown.

Respectfully submitted,

ORDER

GOOD CAUSE APPEARING AND HAVING BEEN SHOWN, IT IS SO ORDERED.

The date for the change of plea hearing is hereby set for December 12, 2014, at 2:00 p.m., before Judge Carolyn K. Delaney and the preliminary hearing in this matter is hereby re-set from December 2, 2014, to December 19, 2014, at 2:00 p.m., before Magistrate Court Judge Allison Claire.