STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE

MORRISON C. ENGLAND, Jr., District Judge.

Plaintiff United States of America, by and through its counsel of record, and defendant Eric Robinson, by and through his counsel of record, hereby stipulate as follows:

1. By previous order, this matter was set for status November 6, 2015.

2. By this stipulation, defendant now moves to continue the status conference until November 12, 2015, and to exclude time between November 6, 2015 and November 12, 2015, under Local Code T4. Plaintiff does not oppose this request.

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 approximately 1, 952 pages of investigative reports and related documents in electronic form and many hours of recorded telephone calls. All of this discovery has been either produced directly to counsel and/or made available for inspection and copying.

b. Counsel for defendant desires additional time to complete the review of discovery, to conduct defense investigation, and to discuss potential resolution with her client. Counsel has also been continuing to engage in negotiations with the government. In particular, Mr. Robinson has a current pending matter in Solano County that the government and counsel are attempting to negotiate a global resolution. Negotiations with the county prosecutor and the government are ongoing. The parties involved have been working diligently to reach a resolution and are very close. An offer has been extended to Mr. Robinson and counsel needs time to discuss this offer with him.

c. Counsel for defendant believes that failure to grant the above-requested continuance would deny her 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 November 6, 2015 to November 12, 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 defendant's 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.

IT IS SO STIPULATED.

ORDER

IT IS SO ORDERED.