STIPULATION AND ORDER TO CONTINUE HEARING AND FOR EXCLUSION OF TIME UNDER THE SPEEDY TRIAL ACT (18 U.S.C. § 3161)

YVONNE GONZALEZ ROGERS, District Judge.

This matter is set for a status conference on September 3, 2015. The parties are continuing to investigate this matter in an effort to find a resolution and have sought the assistance of Pre-trial Services. The parties previously requested a continuance for this reason. The parties have not yet obtained the information requested from Pre-trial Services, but anticipate that the information will be forthcoming. Thus, the parties agree to a second stipulation to continue this status conference date. Accordingly, the parties file this stipulation to continue the hearing to Wednesday, September 23, 2015 at 10:00 a.m., which the Courtroom Deputy confirmed is available, or another date that this Court deems appropriate.1

The parties further agree that time should appropriately be excluded for effective preparation of counsel from September 3, 2015 through Wednesday, September 23, 2015 at 10:00AM in order to provide defense counsel with adequate time to review additional discovery, conduct additional investigation, and consult with the defendant.

In addition, the defendant agrees to exclude for these periods of time any time limits applicable under 18 U.S.C. § 3161. The parties represent that granting the continuance, is necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such a continuance outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

SO STIPULATED.

Based upon the stipulation of the parties to continue the status conference currently set for September 3, 2015 to Wednesday, September 23, 2015 at 10:00 a.m.:

IT IS HEREBY ORDERED that the hearing be continued to Wednesday, September 23, 2015 at 10:00 a.m.:

Based upon the representation of counsel and for good cause shown, the Court further finds that failing to exclude the time between September 3, 2015 and September 23, 2015 would unreasonably deny the defendant and 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 September 3, 2015 and Wednesday, September 23, 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 September 3, 2015 and September 23, 2015 shall be excluded from computation under the Speedy Trial Act. 18 U.S.C §§ 3161(h)(7)(A), 3161(h)(7)(B)(iv).