USA v. Boparai et al

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IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
RAMESH BIRLA,
Defendant
CASE NO. 2:23-CR-00094 DJC
STIPULATION TO CONTINUE
STATUS CONFERENCE; ORDER
Defendant RAMESH BIRLA, by and through his counsel of record, TONI WHITE, and the
GOVERNMENT, by and through Assistant United States Attorney ADRIAN KINSELLA hereby
stipulate as follows:
1. 	By previous order, this matter was set for status conference on December 11, 2025.
2. 	By this stipulation, defendant now moves to continue the status conference until
February 12, 2026, at 9:00 AM, and to exclude time between December 11, 2025 and
February 12, 2026, under 18 U.S.C. § 3161(h)(7)(A), B(iv) [Local Code T4].
3. 	The parties agree and stipulate, and request that the Court find the following:
a) 	Discovery associated with this case includes over 35 gigabytes of evidence in
electronic form, including: investigative reports and related documents, covertly
recorded videos, pictures, and calls; recorded statements by the defendants and
other witnesses, and other evidence. Many of the audio recordings are in the
TONI H. WHITE (SBN 210119)
ATTORNEY AT LAW
P.O. Box 1068
Placerville, CA 95667
Telephone: (530) 885-6244
Attorney for Defendant
RAMESH BIRLA

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Punjabi language. Additional discovery consisted of data and downloads of
multiple cell phones. The defense team has outstanding investigation in progress
and needs additional time to complete those tasks.
b) 	The Government does not object to the continuance.
c) 	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.
d) 	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 December 11, 2025
to February 12, 2026, inclusive, is deemed excludable pursuant to 18
U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4] because it results from a
continuance granted by the Court at defendant’s 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 defendant in a speedy trial.
4. 	Nothing in this stipulation and order shall preclude a finding that other provisions of
the Speedy Trial Act may exclude additional time periods from the period within
which trial must begin.
IT IS SO STIPULATED.
Dated: December 8, 2026 	ERIC GRANT
United States Attorney
By: 	/s/ Adrian Kinsella
ADRIAN KINSELLA
Assistant U.S. Attorney
For the United States
Dated: December 8, 2026 	By: 	/s/ Toni White _
TONI WHITE
For Defendant Ramesh Birla

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O R D E R
IT IS SO FOUND AND ORDERED this 8 th day of December, 2025.
/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE