STIPULATION AND PROPOSED ORDER TO CONTINUE TO JULY 15, 2015

MAXINE M. CHESNEY, District Judge.

The defendant, LOURDES CURCIO, represented by Rebecca Feigelson, and the government, represented by Daniel Talbert, Special Assistant United States Attorney, stipulate to continue the defendants' status hearing, currently set for July 1, 2015, until July 15, 2015. Counsel for the defendant and the government are attempting to negotiate a resolution of this case. The parties anticipate that the July 15, 2015 date can be set on calendar for a change of plea.

The parties further stipulate that, based on the need for counsel to review the proposed resolution of this case, the time between July 1, 2015, and July 15, 2015, be excluded from the Speedy Trial Clock for effective preparation of counsel pursuant to 18 U.S.C. § 3161(h)(7)(A) and (b)(iv).

[PROPOSED] ORDER

Based upon the representations of counsels and for good cause shown, the Court orders that the status hearing for the defendant shall be re-set for July 15, 2015, at 2:30 pm, for change of plea. Based upon the representation of counsel and for good cause shown, the Court finds that failing to exclude the time between July 1, 2015, and July 15, 2015, would unreasonably deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The Court further finds that the ends of justice served by excluding the time between July 1, 2015, and July 15, 2015, from computation under the Speedy Trial Act outweigh the best interests of the public and the defendant in a speedy trial. Therefore, IT IS HEREBY ORDERED that the time between July 1, 2015, and July 15, 2015, shall be excluded from computation under the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).