USA v. Baquedano, et al

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
August Gugelmann, SBN 240544
august@smllp.law
SWANSON & McNAMARA LLP
300 Montgomery Street, Suite 1100
San Francisco, California 94104
Telephone: (415) 477-3800
Facsimile: (415) 477-9010
Attorneys for CARLOS BAQUEDANO
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
vs.
CARLOS ALBERTO BAQUEDANO,
Defendant.
Case No. CR 3-24-71769 MAG
STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE
Defendant Carlos Alberto Baquedano and the United States hereby stipulate and agree as
follows:
1) 	A status conference is currently scheduled for December 16, 2025. The parties are
discussion potential resolution and agree that a continuance of the status conference is needed to
allow continued review of discovery. The government has produced a very large volume of
discovery, including for events across many months and extensive wiretap evidence.
2) 	The parties therefore stipulate and agree and respectfully request that the status
conference be continued to January 22, 2026.
3) 	It is further stipulated that time be excluded under the Speedy Trial Act and Rule
5.1(c) from December 16, 2025 through January 22, 2026. The parties stipulate and agree that
excluding time will allow for the effective preparation of defense counsel. See 18 U.S.C. §
Case 3:24-mj-71769-MRGD Document 76 Filed 12/12/25 Page 1 of 3

2
Stipulation and [Proposed] Order
United States v. Baquedano, CR 3-24-71769 MAG
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
3161(h)(7)(B)(iv). The parties further stipulate and agree that the ends of justice served by
excluding time from computation under the Speedy Trial Act and Rule 5.1(c) outweigh the best
interests of the public and the defendants in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
4) 	The parties further stipulate that there is good cause for extending the time limits
for a preliminary hearing under Federal Rule of Criminal Procedure 5.1. See Fed. R. Crim. P.
5.1(d).
Undersigned defense counsel certifies that he has obtained approval from counsel for the
government to file this stipulation and proposed order.
IT IS SO STIPULATED.
Dated: December 12, 2025 	/s/ 	..
August Gugelmann
SWANSON & McNAMARA LLP
Attorneys for Carlos Alberto Baquedano
/s/ 	..
Kenneth Chambers
Assistant United States Attorney
Case 3:24-mj-71769-MRGD Document 76 Filed 12/12/25 Page 2 of 3

3
Stipulation and [Proposed] Order
United States v. Baquedano, CR 3-24-71769 MAG
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
ORDER
Based on the stipulation of the parties and good cause appearing therefore, the status
conference currently set for December 16, 2025 is continued to January 22, 2026.
Based upon the facts set forth in the stipulation, and for good cause shown, the Court
finds that failing to exclude the time from December 16, 2025 through January 22, 2026, would
unreasonably deny defense counsel and the defendant the reasonable time necessary for effective
preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv).
The Court further finds that the ends of justice served by excluding time from computation under
the Speedy Trial Act and Rule 5.1(c) outweigh the best interests of the public and the defendant
in a speedy trial. Therefore, and with the consent of the parties, IT IS HEREBY ORDERED that
the time from December 16, 2025 through January 22, 2026 shall be excluded from computation
under the Speedy Trial Act and the time period set forth in Rule 5.1(c). 18 U.S.C. §
3161(h)(7)(A), (B)(iv); Rule 5.1(d).
Furthermore, the Court finds that, with the consent of the defendant, there is good cause
for extending the time limits for a preliminary hearing under Federal Rule of Criminal Procedure
5.1. See Fed. R. Crim. P. 5.1(d).
IT IS SO ORDERED.
Dated: December 12, 2025 	____________________________
Hon. Thomas S. Hixson
United States Magistrate Court
Case 3:24-mj-71769-MRGD Document 76 Filed 12/12/25 Page 3 of 3