STIPULATION FOR EXTENSION OF TIME

NANCY J. KOPPE, District Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Daniel G. Bogden, United States Attorney, and Phillip N. Smith, Jr., Assistant United States Attorney, counsel for the United States of America, and Paul D. Riddle, Assistant Federal Public Defender, counsel for Defendant JORGE MONTESINOS-CAMPOS, that the date for the Government to file a response to the Defendant's Motion to Suppress (Docket #27

This stipulation is entered for the following reasons

1. On February 3, 2016, the Defendant filed a Motion to Suppress. See Docket #27. The Government's response deadline was March 14, 2016.

2. The Government has extended an offer to resolve this case, which would obviate the need for the Government to respond to the Defendant's Motion. Counsel for the Defendant has indicated that the Defendant will accept the Government's offer.

3. The parties need additional time to reduce the offer to writing and secure a signature from the Defendant on a plea agreement.

4. The Defendant is incarcerated, but he does not object to the continuance of the Government's response deadline.

5. The additional time requested herein is not sought for purposes of delay, but merely to allow the parties an opportunity to resolve this case, which would obviate the need for further litigation.

6. Additionally, denial of this request for continuance could result in a miscarriage of justice.

7. This is the third stipulation filed herein to continue the Government's response deadline.

8. The parties recently filed a stipulation to continue the trial in this matter. See Docket #33. FINDINGS OF FACT

Based on the pending Stipulation of counsel, and good cause appearing therefore, the Court finds that:

1. On February 3, 2016, the Defendant filed a Motion to Suppress. See Docket #27. The Government's response deadline was March 14, 2016.

2. The Government has extended an offer to resolve this case, which would obviate the need for the Government to respond to the Defendant's Motion. Counsel for the Defendant has indicated that the Defendant will accept the Government's offer.

3. The parties need additional time to reduce the offer to writing and secure a signature from the Defendant on a plea agreement.

4. The Defendant is incarcerated, but he does not object to the continuance of the Government's response deadline.

5. The additional time requested herein is not sought for purposes of delay, but merely to allow the parties an opportunity to resolve this case, which would obviate the need for further litigation.

6. Additionally, denial of this request for continuance could result in a miscarriage of justice.

7. This is the third stipulation filed herein to continue the Government's response deadline.

8. The parties recently filed a stipulation to continue the trial in this matter. See Docket #33.

For all of the above-stated reasons, the ends of justice would best be served by a continuance of the motion response deadline.

CONCLUSIONS OF LAW

The additional time requested herein is not sought for purposes of delay, but merely to allow the parties an opportunity to resolve this case, which would obviate the need for further litigation. The failure to grant said continuance would likely result in a miscarriage of justice.

ORDER

IT IS THEREFORE ORDERED, that the previously-scheduled response deadline for the Government to respond to the Defendant's Motion to Suppress (Docket #27) is extended until March 28, 2016.