STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

JOHN A. MENDEZ, District Judge.

STIPULATION

Plaintiff United States of America, by and through its counsel of record, and defendants Marcus A. Cooper, Tiana Naples, and Leticia A. Roque, by and through their counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status on March 24, 2015, at 9:30 a.m. before Judge John A. Mendez.

2. By this stipulation, defendants now move to continue the status conference until May 19, 2015, at 9:15 a.m. before Judge John A. Mendez, and to exclude time between March 24, 2015, and May 19, 2015, inclusive, under Local Code T4 (to allow defense counsel time to prepare).

3. The parties agree and stipulate, and request that the Court find the following:

a. The government has represented that the discovery associated with this case includes hundreds of pages of discovery, including investigative reports and related documents, as well as several large bags of physical evidence. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. Counsel for defendants desire additional time to consult with their clients, to review the current charges, to conduct investigation and research related to the charges, to review discovery in this matter, and to discuss potential resolutions with their clients.

c. Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

d. The government does not object to the continuance.

e. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the interest of the public and the defendant in a trial within the original date prescribed by the Speedy Trial Act.

f. For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which trial must commence, the time period of March 24, 2015, to May 19, 2015, inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a continuance granted by the Court at defendants' request on the basis of the Court's finding that the ends of justice served by taking such action outweigh the best interest of the public and the defendant in a speedy trial.

4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial must commence.

ORDER

UPON GOOD CAUSE SHOWN and the stipulation of all parties, it is ordered that the status conference presently set for March 24, 2015, be continued to May 19, 2015, at 9:30 a.m. Based on the representation of counsel and good cause appearing therefrom, the Court hereby 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 from March 24, 2015, to and including, May 19, 2015, the 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) [reasonable time for counsel to prepare] (Local Code T4).

IT IS SO ORDERED.