STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF STATUS CONFERENCE AND EXCLUSION OF TIME

EDWARD M. CHEN, District Judge.

The parties in this case agree and jointly request the Court to move the hearing in the above captioned case from September 23, 2015 to November 11, 2015 at 2:30 pm. The basis for this request is that the parties have been in plea discussions and the AUSA is waiting to hear back from the DOJ Tax Division. In addition, the government has more discovery to provide.

The parties concur that granting the exclusion would allow the reasonable time necessary for effective preparation of counsel and continuity of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv). The parties also agree that the ends of justice served by granting such an exclusion of time for the purposes of effective preparation of counsel outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A).

Accordingly, due to the reasons stated above, the parties jointly move to continue the status hearing from September 23, 2015 to November 11, 2015 at 2:30 pm.

IT IS SO STIPULATED.

[PROPOSED] ORDER

For the reasons stated above the Court hereby CONTINUES the hearing in the aforementioned case from September 23, 2015 to November 18, 2015 at 2:30 pm. The Court further finds that the exclusion from the time limits of this period applicable under 18 U.S.C. § 3161 is warranted and that the ends of justice served by the continuance outweigh the best interests of the public and the defendant in a speedy trial. Denying the requested exclusion of time would deprive the defendant effective preparation of counsel, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv).

IT IS SO ORDERED.