AMENDED STIPULATION AND [PROPOSED] ORDER TO CONTINUE STATUS/SETTING HEARING

YVONNE GONAZALEZ ROGERS, District Judge.

A status hearing is currently set in this matter for October 25, 2012 at 2:00 p.m. Defense counsel has another specially set hearing in San Francisco in Case No. CR-12-0194-1 CRB, United States v. Foley at 3:00 p.m. and cannot attend both hearings. In addition, defense counsel requires more time to discuss the possibility of a plea with her client before reporting the status of this matter to the Court. In order to resolve the conflict in hearing times and to give counsel more time to discuss case issues and plea options with her client, the parties hereby stipulate to take this hearing off calendar for October 25, 2012 and present all issues regarding status, a possible plea or trial setting at a hearing on November 1, 2012 at 2:00 p.m.

The parties further stipulate that good cause exists to exclude time between October 25 and November 1, 2012 under the Speedy Trial Act for effective preparation of counsel, to allow defendant to fully consider a proposed plea agreement and for continuity of counsel, in that defense counsel cannot attend both the hearing in this case and the hearing in Case No. CR-12-0194-1 CRB.

[PROPOSED] ORDER

GOOD CAUSE APPEARING THEREFOR, the hearing set for October 25, 2012 at 2:00 p.m. shall be taken off calendar and reset for November 1, 2012 at 2:00 p.m. The Court finds that good cause exists to exclude time between October 25 and November 1, 2012 under the Speedy Trial Act for effective preparation of counsel, to allow defendant to fully consider a proposed plea agreement and for continuity of counsel.

IT IS SO ORDERED.