STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING AND FOR EXCLUSION OF TIME UNDER THE SPEEDY TRIAL ACT

(18 U.S.C. § 3161)

CHARLES R. BREYER, District Judge.

This matter is set for a status conference on October 26, 2016. Counsel for the defendants and the government request that this status conference be continued to December 14, 2016. Defense and government counsel continue to discuss possible resolution of their respective cases. In particular, government counsel is in the process of reviewing the possibility of pretrial diversion for Defendant Jessica Scott and requests additional time to do so. The parties therefore request additional time to prepare their cases and agree that time should appropriately be excluded for effective preparation of counsel from October 26, 2016 through December 14, 2016 for the above-stated reasons.

In addition, the defendants agree 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 October 26, 2016 is continued to December 14, 2016 at 2:00 p.m.

IT IS HEREBY ORDERED that the hearing be continued to December 14, 2016 at 2:00 p.m.

Based upon the representation of counsel and for good cause shown, the Court further finds that failing to exclude the time between October 26, 2016 and December 14, 2016 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 October 26, 2016 and December 14, 2016 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 October 26, 2016 and December 14, 2016 shall be excluded from computation under the Speedy Trial Act. § § 3161(h)(7)(A), 3161(h)(7)(B)(iv).