Joint Stipulation and [Proposed] Order Continuing March 16, 2016, Motion Hearing to April 20, 2016

EDWARD M. CHEN, District Judge.

STIPULATION

Defendant Scott Steever is currently set for motion hearing before the Court on March 16, 2016. Mr. Steever had a transanal protectomy surgery on January 4, 2016. After his surgery he had complications and an infection resulting from wound healing that required daily visiting nurse care. He had carotid artery surgery on March 4, 2016, and is presently recovering.

Due to the unavailability of Mr. Steever for medical reasons the parties are jointly requesting a continuance of the currently set motion hearing date from March 16, 2016, to April 20, 2016, at 2:30 p.m.

Additionally, the parties jointly request an exclusion of time under the Speedy Trial Act from March 16, 2016, to April 20, 2016. In light of Mr. Steever's unavailability due to continuing medical issues and the resulting impact on the investigation, research, and other tasks necessary to prepare a defense and counsel Mr. Steever—additional time is necessary for the effective preparation of counsel. Accordingly, failure to grant a continuance would unreasonably deny Mr. Steever the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. See 18 U.S.C. § 3161(h)(6) and (h)(7).

SO STIPULATED.

[Proposed] Order

For the reasons stated above, the Court continues the motion hearing date from March 16, 2016, to April 20, 2016, at 2:30 p.m.

Time is ordered excluded from March 16, 2016, to April 20, 2016, pursuant to the Speedy Trial Act, 18 U.S.C. § 3161(h)(6) and (h)(7).

SO ORDERED.

IT IS SO ORDERED.