STIPULATION TO CONTINUE STATUS CONFERENCE AND ORDER

LAWRENCE J. O'NEILL, District Judge.

IT IS HEREBY STIPULATED by and between the parties herein that the Status Conference currently scheduled for April 11, 2016, at 8:30 a.m. be continued to May 2, 2016, at 8:30 a.m., before the Honorable Lawrence J. O'Neill.

This request is based upon the fact that counsel for Defendant, Luis Lopez Perez-Concepcion, is working with the U.S. Attorney to resolve the case. Counsel's office was appointed on or about February 17, 2016. Counsel reviewed the plea-plea report and recommendation on or about March 7, 2016. Mr. Perez-Concepcion is a Spanish speaker. Counsel needed to make arrangements to get an interpreter. Mr. Perez-Concepcion is housed in Lerdo. Further arrangements were necessary to have him transported to meet and discuss the pre-plea report. That meeting took place on April 6, 2016. At that time, defense counsel realized that he had not received a proposed plea agreement from the AUSA. Furthermore, defense counsel realized that the assigned AUSA was out on leave. Efforts to contact the AUSA for a proposed plea agreement were immediately undertaken. Those efforts were taken both telephonically and via electronic mail.

This matter is a federal appointed case. All documents and information in the possession of defense counsel have been obtained through PACER. No documents have been received directly from the office of the Federal Public Defender. Defense counsel has not made a formal appearance on the case yet.

Defense counsel has been in contact with AUSA regarding proposed plea agreement. Such agreement is expected to be made available in the next week or so. Once received, it will need to be reviewed with Mr. Perez-Concepcion, once again with the services of a Spanish language interpreter. The AUSA, Mia Giacomazzi, has advised defense counsel that she has no objection to this continuance.

The parties agree that time under the Speedy Trial Act should be excluded under 18 U.S.C. §§ 3161(h)(1)(D) and (7)(A). Defense counsel needs additional time to obtain, review, and consider the proposed plea agreement. Defense counsel has discussed this matter personally with the Defendant using the services of a Spanish language interpreter. The Defendant is agreeable with setting the matter over for anticipated resolution.

It is respectfully submitted that neither the court, nor any party to this proceeding, should be unduly prejudiced by the continuance of the Status Conference for the above-stated purposes.

ORDER

IT IS ORDERED that the Status Conference currently scheduled on April 11, 2016, at 8:30 a.m. is continued to May 2, 2016, at 8:30 a.m. Time under the Speedy Trial Act is excluded through May 2, 2016 under 18 U.S.C. §§ 3161(h)(1)(D) and (7)(A). For the reasons set forth above, the continuance requested is granted for good cause and the court finds the ends of justice outweigh the interest of the public and the defendant in a speedy trial. There will be no further continuances.

IT IS SO ORDERED.