STIPULATION AND [PROPOSED] ORDER EXCLUDING TIME FROM OTHERWISE APPLICABLE SPEEDY TRIAL ACT CALCULATION

WILLIAM ALSUP, District Judge.

STIPULATION

IT IS HEREBY STIPULATED by the parties, through undersigned counsel, that:

1. The parties appeared before the Court on March 10, 2015 at 2:00 p.m. for a status hearing. The defendant, Felipe Velez, was present and represented by Ms. Shilpi Agarwal. Assistant United States Attorney Michael Maffei appeared for the Government. The parties agreed to stipulate to a continuance of the matter to April 14, 2015, with time excluded for effective preparation of counsel from March 10, 2015 through and including March 31, 2015, to allow defense counsel to review previously delivered as well as forthcoming discovery provided by the Government.

2. Accordingly, with the parties' agreement as to the new date, the Court scheduled another status hearing for April 14, 2015 at 2:00 p.m., with the understanding that the parties would submit a Stipulation and Proposed Order excluding only 21 days for purposes of the Speedy Trial Act.

3. The parties now formalize their request for a continuance of this matter to April 14, 2015 at 2:00 p.m. for a further status conference, and respectfully submit and agree that the period from March 3, 2015 through and including March 31, 2015 should be excluded from the otherwise applicable Speedy Trial Act computation because the continuance is necessary for effective preparation of counsel, taking into account the exercise of due diligence. Specifically, the time requested for exclusion will allow defense counsel to review previously delivered as well as forthcoming discovery provided by the Government.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Based upon the above-described Stipulation, THE COURT FINDS THAT the ends of justice served by granting a continuance from March 10, 2015 through and including April 14, 2015 outweigh the best interest of the public and the defendant in a speedy trial, and that failure to grant such a continuance would unreasonably deny the defendant the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

Accordingly, THE COURT ORDERS THAT:

1. The parties shall appear before the Court on April 14, 2015 at 2:00 p.m. for a further status conference.

2. The period from March 10, 2015 through and including March 31, 2015 is excluded from the otherwise applicable Speedy Trial Act computation, pursuant to 18 U.S.C. § 3161(h)(7)(A) & (B)(iv).

IT IS SO ORDERED.