STIPULATION AND (PROPOSED) ORDER TO CONTINUE STATUS CONFERENCE

GARLAND E. BURRELL, JR., District Judge.

Plaintiff United States of America, through its respective counsel, and defendant Juan Carlos Torres-Bobadilla, through his counsel of record, stipulate that the status conference now set for July 12, 2019, be continued to August 16, 2019, at 9:00 a.m.

On May 21, 2019, Mr. Torres-Bobadilla was arraigned on the four-count Indictment in this case. (ECF Nos. 1, 4.) Concurrent with this filing, the government is producing to the defense discovery that includes 841 pages of documents and 13 photos from this investigation. Defense counsel requires time to review these materials, time to conduct additional investigation, time to research potential defenses and motions, and time to otherwise prepare for trial. In addition, defense counsel is in the process of obtaining court records necessary to advise Mr. Torres-Bobadilla.

Based on the foregoing, the parties stipulate that the status conference currently set for July 12, 2019, be continued to August 16, 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 August 16, 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 defendant 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 defendant in a speedy trial.

The Court orders that the time from the date the parties stipulated, up to and including August 16, 2019, shall be excluded from computation of time within which the trial in this case must begin under the Speedy Trial Act, 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 July 12, 2019 status conference be continued until August 16, 2019, at 9:00 a.m.