STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS CONFERENCE AND EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT

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

Plaintiff United States of America by and through Assistant United States Attorney Justin Lee and Defendant Carl Woodruff by and through his attorney Todd D. Leras, request that the Court continue the status conference as to Defendant Woodruff to June 16, 2017, at 9:00 a.m.

This case involves an allegation of child abduction in which relevant actions occurred in the Eastern and Central Districts of California, the District of Nevada, the Eastern District of Virginia, as well as other locations. Defendant Woodruff's investigation of this matter is continuing and can fairly be characterized as nation-wide in scope. Defendant Elena Gutierrez is considering a potential change of plea on Friday, April 21, 2017. Her matter will remain on calendar. Defendant Woodruff alone is requesting continuance of the status conference to complete his separate investigation of matters relevant to his defense. The government does not oppose the request for a continuance.

For the reasons stated in the preceding paragraph, Defendant Carl Woodruff requests continuance of his status conference to June 16, 2017. He also stipulates and agrees to an exclusion of time for the period from April 21, 2017, up to and including June 16, 2017, based on the need for reasonable preparation time. Assistant U.S. Attorney Justin Lee has reviewed this stipulation and proposed order and authorized Todd D. Leras to sign it on his behalf.

ORDER

BASED ON THE REPRESENTATIONS AND STIPULATION OF THE UNITED STATES AND DEFENDANT CARL WOODRUFF, it is hereby ordered that the status conference scheduled for April 21, 2017 is vacated as to Defendant Woodruff. A new status conference is scheduled for Defendant Woodruff on June 16, 2017, at 9:00 a.m. The Court further finds, based on the representations of the United States and Defendant Woodruff, that the ends of justice served by granting the continuance outweigh the best interests of the public and the Defendant in a speedy trial. Time shall be excluded under the Speedy Trial Act, 18 U.S.C. § 3161(h)(7)(B)(4) and Local Code T-4, to allow necessary attorney preparation taking into consideration the exercise of due diligence for the period from April 21, 2017, up to and including June 16, 2017.