STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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

The defendant, DENNIS MACHADO, 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 change of plea on Friday, April 8, 2016 at 9:00 am.

Defense counsel has received a draft plea agreement from the government and a continuance is necessary to allow defense counsel time to review and discuss the proposed plea with his client who was recently transferred to 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 April 8, 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 Michelle Rodriguez to sign and submit this stipulation and proposed order on her behalf.

Accordingly, the defense and the United States agree and stipulate that the status conference for defendant Dennis Machado should be reset for Friday, April 8, 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 change of plea on Friday, April 8, 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, April 8, 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.