USA v. Khanna

1	REQUEST TO CONTINUE DATE AND EXCLUDE TIME;
[PROPOSED] ORDER
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
ERIC GRANT
United States Attorney
VERONICA M.A. ALEGRÍA
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: (916) 554-2700
Facsimile: (916) 554-2900
DAVID L. JAFFE
United States Department of Justice
Chief, Violent Crime & Racketeering Section
CÉSAR S. RIVERA-GIRAUD
Trial Attorney
1301 New York Ave., NW, Suite 715
Washington, DC 20005
Telephone: (202) 878-9352
Facsimile: (202) 307-3944
Attorneys for Plaintiff
United States of America
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
NAVIN KHANNA,
aka Lovin Khanna,
TINU KHANNA,
aka Gagan Khanna,
DANIEL DOLAN, and
CHI MO,
aka David Mo,
NIRMAL KHANNA,
aka Vinnie Khanna,
MICHAEL KHANNA,
ANITA KHANNA,
RICKY VEGA,
ALFREDO MEJIA,
and
VISHNU CHINTAMAN,
Defendants.
CASE NO. 2:22-CR-0213 DC
STIPULATION AND [PROPOSED] ORDER TO
CONTINUE STATUS CONFERENCE DATE AND
EXCLUDE TIME
CURRENT DATE: January 6, 2026
PROPOSED DATE: March 20, 2026
TIME: 9:30 a.m.
COURT: Hon. Dena Coggins

2	REQUEST TO CONTINUE DATE AND EXCLUDE TIME;
[PROPOSED] ORDER
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
STIPULATION
1. By previous order, this matter was set for a status conference on January 6, 2026, for all
of the above-captioned defendants (“defendants”).
2. By this stipulation, defendants now move to continue the status conference until March
20, 2026, and to exclude time between January 6, 2026, and March 20, 2026, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The discovery in this case is voluminous, over 150,000 pages of discovery, as
well as native documents, spreadsheets, and many hours of video and audio recordings.
Additionally, the government has produced 250 GB of additional discovery from multiple other
districts with catalytic converter cases involving DG AUTO, and defense counsel are still
reviewing the newly produced discovery. All of the discovery from this district has been either
produced directly to counsel and/or made available for inspection and copying.
b) Counsel for defendants desire additional time to consult with their clients, review
the discovery, conduct investigation and research related to the charges, and to otherwise prepare
for trial.
c) Counsel for defendant Tinu Khanna has only recently joined the case and needs
additional time to familiarize himself with the discovery.
d) Counsel for defendants believe that failure to grant the above-requested
continuance would deny them the reasonable time necessary for effective preparation, taking into
account the exercise of due diligence.
e) The government does not object to the continuance.
f) The continuance is not based on the congestion of the Court.
g) Based on the above-stated findings, the ends of justice served by continuing the
case as requested outweigh the interest of the public and the defendant in a trial within the
original date prescribed by the Speedy Trial Act.
h) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161,
et seq., within which trial must commence, the time period of January 6, 2026 to March 20,
2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code

3	REQUEST TO CONTINUE DATE AND EXCLUDE TIME;
[PROPOSED] ORDER
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
T4] because it results from a continuance granted by the Court at defendants’ request on the basis
of the Court’s finding that the ends of justice served by taking such action outweigh the best
interest of the public and the defendants in a speedy trial.
4. Nothing in this stipulation and order shall preclude a finding that other provisions of the
Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial
must commence.
IT IS SO STIPULATED.
Dated: January 12, 2026 ERIC GRANT
United States Attorney
/s/ Veronica M.A. Alegría
VERONICA M.A. ALEGRÍA
Assistant United States Attorney
Dated: January 12, 2026 /s/ Daniel B. Olmos
DANIEL B. OLMOS
Counsel for Defendant
NAVIN KHANNA
Dated: January 12, 2026 /s/ Jan Karowsky
JAN KAROWSKY
Counsel for Defendant
TINU KHANNA
Dated: January 12, 2026 /s/ Michael E. Hansen
MICHAEL E. HANSEN
Counsel for Defendant
DANIEL DOLAN
Dated: January 12, 2026 /s/ Kresta Daly
KRESTA DALY
Counsel for Defendant
CHI MO
Dated: January 12, 2026 /s/ John R. Manning
JOHN R. MANNING
Counsel for Defendant
NIRMAL KHANNA

4	REQUEST TO CONTINUE DATE AND EXCLUDE TIME;
[PROPOSED] ORDER
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
Dated: January 12, 2026 /s/ Olaf W. Hedberg
OLAF W. HEDBERG
Counsel for Defendant
MICHAEL KHANNA
Dated: January 12, 2026 /s/ Candice L. Fields
CANDICE L. FIELDS
Counsel for Defendant
ANITA KHANNA
Dated: January 12, 2026 /s/ Robert G. Stahl
ROBERT G. STAHL
LAURA GASIOROWSKI
TIMOTHY E. WARRINER
Counsel for Defendant
RICKY VEGA
Dated: January 12, 2026 /s/ Patrick Keith Hanly
PATRICK KEITH HANLY
Counsel for Defendant
ALFREDO MEJIA
Dated: January 12, 2026 /s/ Tasha Paris Chalfant
TASHA PARIS CHALFANT
Counsel for Defendant
VISHNU CHINTAMAN

1	REQUEST TO CONTINUE DATE AND EXCLUDE TIME;
[PROPOSED] ORDER
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
ORDER
IT IS HEREBY ORDERED as to Defendants Navin Khanna, Tinu Khanna, Daniel Dolan, Chi
Mo, Nirmal Khanna, Michael Khanna, Anita Khanna, Ricky Vega, Alfredo Mejia and Vishnu
Chintaman, the court, having received, read and considered the parties’ stipulation filed on January 6,
2026 (Doc. No. 508), and good cause appearing therefrom, APPROVES the parties’ stipulation.
Accordingly, the Status Conference that was scheduled for January 6, 2026, before Senior District Judge
Kimberly J. Mueller is VACATED and RESET for March 20, 2026 at 9:30 a.m. in Courtroom 10 before
the Honorable Dena M. Coggins. The time period between January 6, 2026 and March 20, 2026,
inclusive, is excluded from computation of time within which the trial of this case must be commenced
under the Speedy Trial Act pursuant to 18 U.S.C.§ 3161(h)(7)(A), and B(iv) [Local Code T4], as the
ends of justice served by granting the continuance outweigh the best interest of the public and the
defendants in a speedy trial.
IT IS SO ORDERED.
Dated: January 12, 2026	___________________________
Dena Coggins
United States District Judge