LUCY H. KOH, District Judge.

TO THE HONORABLE COURT, THE CLERK OF THE COURT, AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

Undersigned defense and government counsel hereby stipulate and request that the current motions hearing and corresponding briefing schedule be modified as set forth in the table below.

A Proposed Order follows.

This stipulation is based upon the following:

1. Immediately following the last appearance in this matter, defense counsel inspected the original evidence at government offices and requested copies of certain documents. The inspection appears sufficient for the issues counsel expects to present to the Court.

2. On April 3, 2013, the government provided additional discovery as requested, consisting of more than six thousand pages of documents, including materials relevant to the intended filing. Defense counsel have been reviewing those materials.

3. Defense counsel have jointly and diligently pursued preparation, including but not limited to conferring and exchanging information and legal authority.

4. In the process of research and drafting, counsel have determined that certain legal issues are better and more clearly raised, answered and decided by the filing of two sets of papers rather than one very long memorandum of points and authorities. In addition, counsel have determined it is not feasible to meet the current filing date.

5. On Friday, April 5, 2013, defense counsel conferred with the Courtroom Deputy and learned that the new proposed hearing date is the next available for the Court.

6. On Monday, April 8, 2013, defense counsel conferred with SAUSA Charles Parker, who agrees to the modification of dates and jointly stipulates to this request.

This is the first request for additional time in connection with the instant motions. Defendants are not in custody. Undersigned defense counsel believe that the additional time is necessary to the interests of justice and for effective preparation of counsel, and is sufficient to complete the preparation of the motions to be filed at that time. Government counsel does not object. The current and proposed new dates are as follows:

For these reasons, IT IS STIPULATED AND AGREED that time under the Speedy Trial Act be excluded from May 15, 2013 until June 5, 2013, because the ends of justice outweigh the best interest of the public and the defendant in a speedy trial, for effective preparation of defense counsel, and taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).

[PROPOSED] ORDER

Good cause appearing therefore, IT IS ORDERED that time under the Speedy Trial act be excluded until from May 15, 2013 through and including June 5, 2013, because the interests of justice outweigh the best interests of the public and defendant in a speedy trial, for effective preparation of defense counsel, and taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). Defense counsel shall notify their clients of the new dates and that they are ORDERED to appear at the new hearing.