STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jason Hitt, and defendant, Thomas Nelson Keys, by and through his attorney, Erin J. Radekin, agree and stipulate to vacate the date currently set for status conference, March 31, 2017 at 9:00 a.m., in the above-captioned matter, and to continue the status conference to June 16, 2017 at 9:00 a.m. in the courtroom of the Honorable Garland E. Burrell, Jr.

The reason for this request is that the defense has requested additional discovery and the government has agreed to provide it. In addition, the defense needs additional time for investigation, plea negotiations, and other defense preparation. The Court is advised that Mr. Hitt concurs with this request and has authorized Ms. Radekin to sign this stipulation on his behalf.

The parties further agree and stipulate that the time period from the filing of this stipulation until June 16, 2017 should be excluded in computing time for commencement of trial under the Speedy Trial Act, based upon the interest of justice under 18 U.S.C. § 3161(h)(7)(B)(iv), and Local Code T4, to allow reasonable time necessary for effective defense preparation. It is further agreed and stipulated that the ends of justice served in granting the request outweigh the best interests of the public and the defendant in a speedy trial.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED.

ORDER

For the reasons set forth in the accompanying stipulation and declaration of counsel, the status conference date of March 31, 2017 at 9:00 a.m. is VACATED and the above-captioned matter is set for status conference on June 16, 2017 at 9:00 a.m. The Court finds excludable time in this matter through June 16, 2017 under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4, to allow reasonable time necessary for effective defense preparation. For the reasons stipulated by the parties, the Court finds that the interest of justice served by granting the request outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §§ 3161(h)(7)(A), (h)(7)(B)(iv).

IT IS SO ORDERED.