REVISED JOINT STIPULATION FOR CONTINUANCE AND EXCLUSION OF TIME FROM NOVEMBER 8, 2016 TO DECEMBER 20, 2016 AND ORDER

BETH L. FREEMAN, District Judge.

JOINT STIPULATION

On September 20, 2016, the parties appeared before the Honorable Beth L. Freeman for a status conference. At the hearing, counsel informed the Court that additional time was needed to evaluate potential resolutions of the case. The parties agreed to a continuance and the matter was placed on the Court's calendar for November 8, 2016, at 9:00 a.m., for a status hearing or change of plea.

Prior to the November 8, 2016 hearing, the parties conferred and determined that the defendant needs additional time to review the government's edits to the proposed plea agreement. Accordingly, the parties jointly request a continuance until December 20, 2016, at 9:00 a.m., for change of plea.

The parties hereby stipulate that the time between November 8, 2016 and December 20, 2016, at 9:00 a.m., should be excluded from the period of time within which the defendant's trial must commence pursuant to the Speedy Trial Act in order to allow each counsel sufficient time to effectively prepare, taking into account the exercise of due diligence. Furthermore, the parties stipulate that the ends of justice served by granting the request outweigh the best interest of the public and the defendant in a speedy trial.

ORDER

Based upon the stipulation of the parties, and for good cause shown, the COURT HEREBY ORDERS that the hearing currently scheduled for November 8, 2016 is vacated and continued to December 20, 2016, at 9:00 a.m. The Court FURTHER ORDERS that the time between November 8, 2016 and December 20, 2016, at 9:00 a.m., is excluded under the Speedy Trial Act, Title 18, United States Code, Sections 3161(h)(7)(A) and 3161(h)(7)(B)(iv). The Court finds that the failure to grant this request would unreasonably deny each counsel sufficient time to effectively prepare, taking into account the exercise of due diligence. Furthermore, the Court finds that the ends of justice served by granting the request outweigh the best interest of the public and the defendant in a speedy trial and in the prompt disposition of criminal cases.

The Court therefore concludes that this exclusion of time should be made under Title 18, United States Code, Sections 3161(h)(7)(A) and 3161(h)(7)(B)(iv).