STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

EDWARD M. CHEN, District Judge.

This matter is currently set for a status conference on March 28, 2018, at 2:30 p.m. The parties hereby stipulate to vacate that date and reset the status conference for Wednesday, April 25, 2018, at 2:30 p.m. Defense counsel is requesting that the status conference be continued to April 25, 2018, at 2:30 p.m., to allow counsel sufficient time to adequately prepare the defense. In particular, the parties are discussing a potential resolution of the case, and defense counsel needs additional time to discuss the discovery, case strategy, and the terms of any proposed resolution with Ms. Buenaventura. A continuance of this status conference will allow defense counsel the reasonable time necessary for effective preparation.

The defendant and the government consent to the extension of time, and the parties represent that good cause exists for this extension, including the effective preparation of counsel. The parties agree that the time between March 28, 2018 and April 25, 2018 should be excluded under the Speedy Trial Act pursuant to 18 U.S.C. §3161(h)(7)(A) and (h)(7)(B). The parties also agree that the ends of justice are served by granting an extension of time and that an exclusion of time outweighs the best interests of the public and the defendant in a speedy trial. See 18 U.S.C. §3161(h)(7)(A).

SO STIPULATED.

[PROPOSED] ORDER

For the reasons stated above, the Court continues the above entitled matters to Wednesday, April 25, 2018, at the hour of 2:30 p.m. The court also finds that the exclusion of this period from the time limits applicable under 18 U.S.C. §3161 is warranted, and that the ends of justice served by the continuance outweigh the interests of the public and the defendant in a speedy trial for the periods from March 28, 2018 and April 25, 2018. See 18 U.S.C. §3161(h)(7)(A); and that the failure to grant the requested exclusion of time would deny counsel for the defendant the reasonable time necessary for effective preparation and continuity of counsel, taking into account the exercise of due diligence, and would result in a miscarriage of justice. See 18 U.S.C. §3161(h)(7)(B)(iv).

IT IS SO ORDERED.