USA v. Lucero-Peace et al

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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
JEFF MITCHELL (CABN 236225)
Chief, Criminal Division
NEAL C. HONG (ILBN 6309265)
Assistant United States Attorney
60 S. Market, Suite 1200
San Jose, California 95113
Telephone: (408) 535-5081
neal.hong@usdoj.gov
Attorneys for United States of America
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JONATHAN LUCERO PEACE,
Defendant.
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Case No. 26-CR-00048-1 EKL
STIPULATION TO CONTINUE STATUS
HEARING AND EXCLUDE TIME UNDER THE
SPEEDY TRIAL ACT AND [PROPOSED] ORDER
Currently, there is a status conference scheduled for August 25, 2026. The Government has
produced discovery to the defense. Counsel for Defendant has reviewed the discovery but requires
additional time to review certain matters to effectively prepare Defendant’s case. Accordingly, the
parties respectfully request that the Court continue the status conference scheduled for August 25, 2026,
to November 3, 2026.
The parties stipulate and agree that excluding time until November 3, 2026, will allow for the
effective preparation and continuity of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv). The parties further
stipulate and agree that the ends of justice served by excluding the time from August 25, 2026, to
November 3, 2026, from computation under the Speedy Trial Act outweigh the best interests of the
Case 5:26-cr-00048-EKL Document 69 Filed 08/20/26 Page 1 of 3

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public and Defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
IT IS SO STIPULATED 	CRAIG H. MISSAKIAN
United States Attorney
Dated: August 19, 2026 	/s/ Neal Hong________________
NEAL C. HONG
Assistant United States Attorney
/s/ Naomi Chung_________________
NAOMI CHUNG
Counsel for Defendant
Case 5:26-cr-00048-EKL Document 69 Filed 08/20/26 Page 2 of 3

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, and for good cause shown, the Court hereby continues the
status conference to August 25, 2026, and excludes time under the Speedy Trial Act from August 25,
2026, to November 3, 2026. The Court finds that failing to exclude the time from August 25, 2026, to
November 3, 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 the time from
August 25, 2026, to November 3, 2026, from computation under the Speedy Trial Act 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 August 25, 2026, to November 3, 2026, shall be
excluded from computation under the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
IT IS SO ORDERED.
DATED: ___________________
HON. EUMI K. LEE
United States District Judge
August 20, 2026
Case 5:26-cr-00048-EKL Document 69 Filed 08/20/26 Page 3 of 3