STIPULATION AND ORDER

JOHN A. MENDEZ, District Judge.

Plaintiff United States of America, by and through its counsel of record, and the Defendant, by and through each counsel of record, hereby stipulate as follows:

1. Attorney Hedberg needs additional time to review discovery and needs time to review it with his client. Further, Defendant has a significant immigration issue and further research is needed to determine the impact of resolution of this case upon her immigration status.

2. By this stipulation, the defendant now move to continue the status conference until December 18, 2014, and to exclude time between December 15, 2015, and February 2, 2016 at 9:15 a.m., 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 provided discovery associated with this case soon.

b. Counsel for the defendant desires time to consult with his client, to review the current charges, to conduct investigation and research related to the charges, to review and copy discovery for this matter and to discuss potential resolutions with his client.

c. Counsel for the defendant believes 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 December 15, 2015, to February 2, 2016, 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

GOOD CAUSE APPEARING, it is hereby ordered that the December 15, 2015 status conference be continued to February 2, 2016 at 9:15 a.m. I find that the ends of justice warrant an exclusion of time and that the defendant's need for continuity of counsel and reasonable time for effective preparation exceeds the public interest in a trial within 70 days. THEREFORE IT IS FURTHER ORDERED that time be excluded pursuant to 18 U.S.C. § 3161 (h) (7) (B) (ii) and Local Code T4 from the date of this order to February 2, 2016.

IT IS SO ORDERED.