STIPULATION TO EXTEND FILING DATE OF YAOWAPHA RITDET'S REPLY TO GOVERNMENT'S OPPOSITION TO MOTION TO SUPPRESS AND [PROPOSED] ORDER THEREON

EDWARD M. CHEN, District Judge.

On February 16, 2016, in response to a Stipulation filed by the parties, the Court extended the hearing date on Defendant Yaowapha Ritdet's Motion to Suppress to March 23, 2016. On February 24, 2016, the parties filed a Stipulation For Limited Unsealing of Search Warrant Documents and [Proposed] Order, which was granted by the Court on February 25, 2016. This Stipulation was filed in order to allow the Government to provide to Ms. Ritdet and Mr. Walter the search warrants, applications and affidavits as to the searches of the two restaurants owned by Ms. Ritdet and the personal residence of Ms. Ritdet and her husband, co-Defendant, Steve Walter.

In order to give Ms. Ritdet and her counsel sufficient time in which to receive and review the documents anticipated to be provided by the Government that which are relevant to the Motion to Suppress, the parties have agreed, and respectfully request that the Court order, to extend the due date for the filing of Ms. Ritdet's Reply to the Government's Opposition to the Motion to Suppress by one week to March 9, 2016 at 2:30 p.m. before the Honorable Edward M. Chen.

The Parties in the above-captioned case agree and jointly request:

1. That the date currently set for the filing of Ms. Ritdet's Reply to the Government's Opposition to Motion to Suppress currently due on Wednesday, March 2, 2016, be extended to Wednesday, March 9, 2016;

2. That the current hearing date on the Motion to Suppress, March 23, 2016, at 2:30 p.m. before the Honorable Edward M. Chen be maintained; and

3. That, to the extent necessary, the period of delay from March 2, 2016 through March 9, 2016, be excluded in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. §§ 3161(h)(7)(A) and (h)(7)(B)(iv), as the ends of justice served by this extension allow for effective preparation, continuity of counsel and adequate trial preparation, which outweigh the best interests of the public and the Defendants in a speedy trial.

ORDER

For the reasons stated by the parties in their Stipulation, the Court finds that the ends of justice are served by:

1. Extending the filing date for Yaowapha Ritdet's Reply to the Government's Opposition to her Motion to Suppress from March 2, 2016, to March 9, 2016, to allow Ms. Ritdet and her counsel sufficient time to receive and review documents to be provided by the Government relevant to the Motion to Suppress pursuant to this Court's order dated February 25, 2016, and effective preparation, continuity of counsel and adequate trial preparation;

2. Maintaining the current hearing date on the Motion to Suppress, March 23, 2016 at 2:30 (or as soon thereafter as Adam Penella, counsel for Steve Walter, can arrive following the conclusion of his appearance for a Status Conference in front of the Honorable Judge Charles R. Breyer scheduled to commence at 2:00 p.m. on March 23, 2016); and

3. Excluding the period of delay from March 2, 2016 through March 9, 2016, as necessary, in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. §§3161(h)(7)(A) and (h)(7)(B)(iv), as the ends of justice served by this exclusion allow for effective preparation, continuity of counsel and adequate trial preparation, which outweigh the best interests of the public and the Defendants in a speedy trial.

IT IS HEREBY ORDERED that the due date for the filing of Ms. Ritdet's Reply to the Government's Opposition to her Motion to Suppress shall be moved to March 9, 2016.

IT IS FURTHER HEREBY ORDERED that the current hearing date on Ms. Ritdet's Motion to Suppress, March 23, 2016, shall be maintained.

IT IS FINALLY HEREBY ORDERED that the period of delay from March 2, 2016 to March 9, 2016, shall be excluded as necessary in accordance with the provisions of the Speedy Trial Act, 18 U.S.C. §§3161(h)(7)(A) and (h)(7)(B)(iv), as the ends of justice served by this exclusion allow for effective preparation, continuity of counsel and adequate trial preparation, which outweigh the best interests of the public and the Defendants in a speedy trial.