2:25-cr-00247•USA v. Tolentino et al
Gesamter Gesetzestext
1 S TIPULATION REGARDING EXCLUDABLE TIME P ERIODS U NDER S PEEDY TRIAL A CT 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 ERIC GRANT United States Attorney ROBERT C. ABENDROTH NICOLE M. VANEK Assistant United States Attorneys 501 I Street, Suite 10-100 Sacramento, CA 95814 Telephone: (916) 554-2700 Facsimile: (916) 554-2900 Attorneys for Plaintiff United States of America IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. LLOYD LISTER, ELMER MONTIEL-ROMERO, LEON JAMES WHITELEY, LYLE COOPER, JUAN MUNOZ-GUZMAN, COY MOBLEY, JESSICA PACK, BRANDI EMERSON, BRIAN SEDGWICK, and VANESSA FLORES-GOMEZ, Defendants. CASE NO. 2:25-CR-00247-DJC STIPULATION TO CONTINUE STATUS CONFERENCE AND TO EXCLUDE TIME PERIODS UNDER THE SPEEDY TRIAL ACT AND ORDER STIPULATION 1. By previous order, this matter was set for status on January 8, 2026. 2. By this stipulation, the parties now move to continue the status conference until April 16, 2026, and to exclude time between January 8, 2026, and April 16, 2026, under Local Codes T2 and T4. 3. The parties agree and stipulate, and request that the Court find the following: a) The Defendants appeared in the Eastern District of California on the indictment and initial discovery has been sent to counsel for the Defendants. The government intends to
2 S TIPULATION REGARDING EXCLUDABLE TIME P ERIODS U NDER S PEEDY TRIAL A CT 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 send additional discovery in January 2026 which will be sent to defense counsel pursuant to a Protective Order entered by the Court on December 18, 2025. Counsel for the government and the defendants require additional time to coordinate the transmission of discovery pursuant to the Protective Order. b) The discovery in this matter is quite voluminous consisting of electronic data and materials collected during Court-authorized interception of wire and electronic communications. The discovery consists of multiple gigabytes of data. Given the amount of discovery and the number of defendants, this case is unusually complex such that setting trial within the timeframe outlined in the Speedy Trial Act would be unreasonable. c) Counsel for defendants will require additional time to review the discovery materials and charges, conduct investigation, conduct research related to the charges, to assess the viability of any pretrial motions, and arrange for in-person visits to discuss potential resolutions with their clients. 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) 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 defendants in a trial within the original date prescribed by the Speedy Trial Act. f) 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 8, 2026 to April 16, 2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), (B)(ii) and (iv) [Local Codes T2 and T4] because it results from a continuance granted by the Court at the parties’ 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. / / / / / /
3 S TIPULATION REGARDING EXCLUDABLE TIME P ERIODS U NDER S PEEDY TRIAL A CT 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 4. Nothing in this stipulation and order shall preclude a finding that other provisions of the Speedy Trial Act warrant time periods excludable from the period within which a trial must commence. IT IS SO STIPULATED. Respectfully Submitted, Dated: January 2, 2026 By: ERIC GRANT United States Attorney /s/ ROBERT ABENDROTH ROBERT ABENDROTH Assistant United States Attorney Dated: January 2, 2026 /s/ F. PHILLIP COZENS F. PHILLIP COZENS Counsel for Defendant LLOYD LISTER Dated: January 2, 2026 /s/ JAYA C. GUPTA JAYA C. GUPTA Counsel for Defendant ELMBER MONTIEL-ROMERO Dated: January 2, 2026 /s/ MICHAEL LONG MICHAEL LONG Counsel for Defendant LEON JAMES WHITELEY Dated: January 2, 2026 /s/ PETER JONES PETER JONES Counsel for Defendant LYLE COOPER Dated: January 2, 2026 /s/ CLEMENTE JIMENEZ CLEMENTE JIMENEZ Counsel for Defendant JUAN MUNOZ-GUZMAN Dated: January 2, 2026 /s/ REBECCA LEVY REBECCA LEVY Counsel for Defendant COY MOBLEY
4 S TIPULATION REGARDING EXCLUDABLE TIME P ERIODS U NDER S PEEDY TRIAL A CT 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 Dated: January 2, 2026 /s/ ANA BOTELLO ANA BOTELLO Counsel for Defendant JESSICA PACK Dated: January 2, 2026 /s/ ANTHONY CAPOZZI ANTHONY CAPOZZI Counsel for Defendant BRANDI EMERSON Dated: January 2, 2026 /s/ OLAF HEDBERG OLAF HEDBERG Counsel for Defendant BRIAN SEDGWICK Dated: January 2, 2026 /s/ ERIC KERSTEN ERIC KERSTEN Counsel for Defendant VANESSA FLORES-GOMEZ ORDER IT IS SO FOUND AND ORDERED this 5 th day of January, 2026. /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE
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