STIPULATION AND [PROPOSED] ORDER

EDWARD M. CHEN, District Judge.

WHEREAS, on July 6, 2011, Maher Kara pled guilty and agreed to cooperate with the government's ongoing insider trading investigation;

WHEREAS, on July 13, 2011, Mounir Kara pled guilty and agreed to cooperate with the government's ongoing insider trading investigation;

WHEREAS, on September 1, 2011, Bassam Yacoub Salman was indicted on charges related to this insider trading scheme;

WHEREAS, on May 9, 2012, the Court scheduled trial in United States v. Salman to begin on March 4, 2013;

WHEREAS, the parties (1) now anticipate that Maher Kara and Mounir Kara will both be witnesses for the government in the upcoming trial pursuant to their respective cooperation agreements; (2) request that the sentencing hearings for their respective cases be adjourned until after the March 4, 2013 trial so they may complete their cooperation; and (3) request that the status conference in these cases now scheduled for December 12, 2012 at 2:30 p.m. therefore be postponed to a date that is convenient for the Court in June 2013.

THEREFORE, it is hereby stipulated by and between the parties, through their respective counsel of record, that the time from December 12, 2012 to a date that is convenient for the Court in June 2013 shall be excluded in computing the time within which the trial of the offense alleged in the Indictment must commence under Title 18, United States Code, Section 3161 for defendants Maher Kara and Mounir Kara.

On the basis of material submitted to the Court,

IT IS HEREBY ORDERED that:

The ends of justice are served by finding that a continuance of the status hearing for defendants Maher Kara and Mounir Kara from December 12, 2012 to June 19, 2013 outweighs the best interests of the public and the defendants in a speedy trial and the prompt disposition of criminal cases and the Court concludes that the exclusion of time from December 12, 2012 to June 19, 2013 should be made under Title 18, United States Code, Sections 3161(h)(7)(B)(iv).