MORRISON C. ENGLAND, Jr., Chief District Judge.
The defendant, KAYODE GEORGE GANSAH, by and through his undersigned counsel and the United States by and through its undersigned counsel, hereby stipulate and request that the status conference currently set for Thursday, April 9, 2015 at 9:00 am be vacated and reset for Thursday, May 7, 2015 at 9:00 am.
A continuance is necessary because defense counsel is still in trial in Sacramento County Superior Court in the matter of People v. Aguilera, case no. 11F06897. A continuance is also necessary to allow the defense time to receive additional discovery and conduct further investigation.
The parties further stipulate that the failure to grant a continuance in this matter would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence; that the ends of justice served by granting this continuance outweigh the best interest of the public and the defendant in a speedy trial; and that time should be excluded from the computation of time within which trial must commence under the Speedy Trial Act from April 9, 2015, up to and including May 7, 2015, 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.
I, William E. Bonham, the filing party, have received authorization from AUSA Jason Hitt to sign and submit this stipulation and proposed order on his behalf.
Accordingly, the defense and the United States agree and stipulate that the status conference for defendant Kayode George Gansah should be reset for Thursday, May 7, 2015 at 9:00 am before the Honorable Morrison C. England, Jr.
IT IS SO ORDERED. The status conference currently set for Thursday, April 9, 2015 at 9:00 am is vacated and reset for Thursday, May 7, 2015, at 9:00 am. The failure to grant such a continuance would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. Accordingly, the time within which the trial of this case must be commenced under the Speedy Trial Act is excluded from April 9, 2015, up to and including the date of the new status conference, May 7, 2015, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T4 and 18 U.S.C. § 3161(h)(1)(D) and Local Code E upon the filing of motions. I specifically find that the ends of justice served by granting this continuance outweigh the best interest of the public and defendants in a speedy trial within the meaning of 18 U.S.C. § 3161(h) (7) (A) and (B) (IV) and Local Code T-4.