STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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

The defendant, DAVID HOMAN, by and through his undersigned counsel and the United States by and through its undersigned counsel, hereby agree and request that the status conference currently set for Friday, March 4, 2016 at 9:00 am be vacated and reset for Friday, March 25, 2016 at 9:00 am.

A continuance is necessary for further plea negotiations and to allow the government time to provide a revised plea agreement, as well as, to allow defense counsel time to review and discuss the proposed plea with his client who is housed in the Nevada City Jail.

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 March 4, 2016, up to and including March 25, 2016, 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 David Homan should be reset for Friday, March 25, 2016 at 9:00 am before the Honorable Garland E. Burrell, Jr.

ORDER

The status conference currently set for Friday, March 4, 2016 at 9:00 am is vacated and reset for Friday, March 25, 2016, at 9:00 am.

I find that 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 March 4, 2016, up to and including the date of the new status conference, March 25, 2016, pursuant to 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) and Local Code T4. 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.