Opinion
BENJAMIN B. WAGNER, United States Attorney, HENRY CARBAJAL Assistant United States Attorney for Plaintiff
HEATHER E. WILLIAMS, Federal Defender, CHARLES J. LEE, Assistant Federal Defender Attorneys for Defendant KENNETH MANUEL MARTIN
STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE HEARING
IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel that the status conference in the above-captioned matter now set for February 9, 2015, may be continued to April 13, 2015 at 1:00 p.m. before Magistrate Barbara A. McAuliffe.
This continuance is at the request of defense counsel as defense needs additional time in preparation of this case. Government counsel has provided a new offer to defense counsel on January 13, 2015. Defense needs additional time to fully review the terms of the plea agreement and meet with client to discuss and answer all questions regarding both the plea agreement and numerous collateral consequences. Additionally, a small amount of new discovery was recently provided to defense counsel and defense would like to conduct some further investigation on the case.
The requested continuance is with the intention of conserving time and resources for both parties and the court. The parties agree that the delay resulting from the continuance shall be excluded in the interests of justice, including but not limited to, the need for the period of time set forth herein for effective defense preparation and plea negotiation purposes pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
ORDER
IT IS SO ORDERED that the 9th Status Conference is continued from February 9, 2015 to April 13, 2015 at 1:00 PM before Judge McAuliffe. Time is excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(i) and (iv).
IT IS SO ORDERED.