STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

GARLAND E. BURRELL, JR., District Judge.

Plaintiff United States of America, through its undersigned counsel, and defendants Miguel Alverez Cervantes, Maria Cervantes-Echevarria, and Marta Jiminez Lopez, through their counsel of record, stipulate that the status conference now set for March 29, 2019, be continued to May 10, 2019, at 9:00 a.m.

On October 2, 2018, all three defendants were arraigned on the eight-count Indictment. (ECF Nos. 15, 18.) In the weeks following, the government produced to the defense discovery that included 97 pages of reports and memoranda, approximately 250 photos, and a litany of audio and video recordings from this investigation. Defense counsel for all three defendants require additional time to review these materials and discuss them with their clients, time to conduct research into any potential suppression issues or motions to dismiss, time to conduct additional investigation, and time to otherwise prepare for trial.

Based on the foregoing, the parties stipulate that the status conference set for March 29, 2019, be continued to May 10, 2019, at 9:00 a.m. The parties further agree that time under the Speedy Trial Act should be excluded from the date the parties stipulated, up to and including May 10, 2019, under 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare], and General Order 479, [Local Code T4], based on continuity of counsel and defense preparation.

The parties agree that the failure to grant a continuance in this case would deny defense counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The parties also agree that the ends of justice served by the Court granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.

ORDER

The Court, having received and considered the parties' stipulation, and good cause appearing therefore, adopts the parties' stipulation in its entirety as its order. The Court specifically finds that the failure to grant a continuance in this case would deny counsel reasonable time necessary for effective preparation, taking into account the exercise of due diligence. The Court also finds that the ends of justice served by granting the requested continuance outweigh the best interests of the public and the defendants in a speedy trial.

The Court orders that the time from the date the parties stipulated, to and including May 10, 2019, shall be excluded from computation of time within which the trial in this case must be commenced under the Speedy Trial Act, see 18 U.S.C. § 3161(h)(7)(A) and (B)(iv) [reasonable time to prepare], and General Order 479 [Local Code T4]. It is further ordered that the March 29, 2019 status conference be continued to May 10, 2019, at 9:00 a.m.