STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME

GARLAND E. BURRELL, Jr., Senior District Judge.

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, JOSH SIGAL, Assistant United States Attorney, attorney for Plaintiff, DOUGLAS J. BEEVERS, attorney for JOSE MILLAN, and CLEMENTE JIMENEZ, attorney for MIGUEL RODRIGUEZ that the status conference hearing date of February 13, 2015 be vacated, and the matter be set for status conference on March 20, 2015 at 9:00 a.m.

The reasons for this continuance are to allow defense counsel additional time to review discovery, to examine possible defenses and to continue investigating the facts of the case.

Based upon the foregoing, the parties agree that the time under the Speedy Trial Act should be excluded from the date of signing of this order through and including March 20, 2015 pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare] and Local Code T4 based upon continuity of counsel and defense preparation.

Respectfully submitted.

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the February 13, 2015, status conference hearing be continued to March 20, 2015, at 9:00 a.m. Based on the representation of defense counsel and good cause appearing there from, the Court hereby finds that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds that the ends of justice to be served by granting a continuance outweigh the best interests of the public and the defendant in a speedy trial. It is ordered that time up to and including the March 20, 2015 status conference shall be excluded from computation of 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)(A) and (B)(iv) and Local Code T-4, to allow defense counsel reasonable time to prepare.