STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME UNDER THE SPEEDY TRIAL ACT FROM JANUARY 15, 2013 THROUGH FEBRUARY 26, 2013 AND FROM MARCH 26, 2013 THROUGH MAY 21, 2013.

RICHARD SEEBORG, District Judge.

On January 15, 2013, the parties in this case appeared before the Honorable Richard Seeborg for a status conference. At that time, defense counsel stated that she would need some additional time to review conduct additional investigation in order to determine whether to file a motion to suppress. The parties jointly requested an extension of time until February 26, 2013 and stipulated that time should be excluded from January 15, 2013 to February 26, 2013 for effective preparation of defense counsel and continuity of counsel. The parties represented that granting the continuance was for the reasonable time necessary for effective preparation of defense counsel, taking into account the exercise of due diligence. See 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).

The parties also agreed that the ends of justice served by granting such a continuance outweighed the best interests of the public and the defendants in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A).

On March 26, 2013, the parties again appeared before the Court for a status conference. At that time, the parties represented that the defendant had obtained new counsel and that the defense was conducting further investigation into the defendant's prior conviction records in order to inform the parties' ongoing plea negotiations. The parties also represented that defense counsel would be away from the office for a large portion of April. The parties jointly requested an extension of time until May 21, 2014 for entry of plea and stipulated that time should be excluded from March 26, 2013 to May 21, 2013 for effective preparation of defense counsel and continuity of counsel. The parties represented that granting the continuance was for the reasonable time necessary for effective preparation of defense counsel, taking into account the exercise of due diligence. See 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).

The parties also agreed that the ends of justice served by granting such a continuance outweighed the best interests of the public and the defendants in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A).

IT IS SO STIPULATED:

IT IS HEREBY ORDERED that time is excluded under the Speedy Trial Act from January 15, 2013 to February 26, 2013 and from March 26, 2013 to May 21, 2013, under 18 U.S.C. § 3161(B)(iv) and 18 U.S.C. § 3161(h)(7)(A).

IT IS SO ORDERED.