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 January 12, 2015, should be continued until February 17, 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 January 12, 2015, and the parties continue to jointly agree that time should continue to be excluded until February 17, 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 February 17, 2015.

IT IS STIPULATED that the period of time from the signing of this Order up to and including the new court date of February 17, 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.

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for January 12, 2015, at 9:30 a.m. be continued to February 17, 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 February 17, 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.