STIPULATION AND [PROPOSED] ORDER TO VACATE STATUS CONFERENCE, SET CHANGE OF PLEA AND EXCLUDE TIME

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

IT IS HEREBY STIPULATED by and between Benjamin Wagner, U.S. Attorney, through Rosanne Rust, Assistant United States Attorney, attorney for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender, Jerome Price, attorney for John K. Cabrera, that the status conference scheduled for March 18, 2016 be vacated and set for a change of plea hearing for March 25, 2016 at 9:00 a.m.

Defense counsel requires additional time to prepare and consult with the defendant.

Based upon the foregoing, the parties agree time under the Speedy Trial Act should be excluded of this order's date through and including March 25, 2016; pursuant to 18 U.S.C. §3161 (h)(7)(A)and (B)(iv)[reasonable time to prepare] and General Order 479, Local Code T4 based upon continuity of counsel and defense preparation.

Counsel and the defendant also agree that the ends of justice served by the Court granting this continuance outweigh the best interests of the public and the defendant in a speedy trial.

Respectfully submitted.

ORDER

IT IS HEREBY ORDERED, the Court, having received, read, and considered the parties' stipulation, and good cause appearing therefrom, adopts the parties' stipulation in its entirety as its order. The Court specifically finds the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court finds the ends of justice are served by granting the requested continuance and outweigh the best interests of the public and defendant in a speedy trial.

The Court orders the time from the date the parties stipulated, up to and including March 25, 2016, shall be excluded from computation of time within which the trial of this case 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] and General Order 479, (Local Code T4). It is further ordered the March 18, 2016 status conference shall be vacated and a change of plea hearing be set for March 25, 2016, at 9:00 a.m.