USA v. Nguyen

STIPULATION AND [PROPOSED] ORDER
NGUYEN, 26-CR-70438 MAG
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JODI LINKER
Federal Public Defender
Northern District of California
DEJAN M. GANTAR
Assistant Federal Public Defender
8th Floor - Suite 820
55 South Market Street
San Jose, CA 95113
Telephone: (408) 291-7753
Facsimile: (408) 291-7399
Email: Dejan_Gantar@fd.org
Counsel for Defendant NGUYEN
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
HOANG NGUYEN,
Defendant.
Case No.: 26-CR-70438 MAG (NC)
STIPULATION TO CONTINUE STATUS
CONFERENCE; [PROPOSED] ORDER
STIPULATION
Defendant Hoang Nguyen, represented by AFPD Dejan M. Gantar, and the Government,
represented by AUSA Kenneth Chambers, respectfully request that the status conference currently
scheduled for October 13, 2026 be continued until December 18, 2026.
The parties make this request so that the parties have additional time to continue working toward
a potential resolution, and for defense counsel to review discovery and confer with his client.
The parties further stipulate and agree that the time between October 1, 2026 and December 18,
2026 be excluded to allow for effective preparation of counsel, taking into account the exercise of due
diligence, and that the ends of justice served by granting the request outweigh the best interests of the
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STIPULATION AND [PROPOSED] ORDER
NGUYEN, 26-CR-70438 MAG
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public and the defendant in a speedy trial. The parties further stipulate and agree that, given the need
to investigate matters which may bear on the disposition in the case, good cause exists for extending
the time limits for a preliminary hearing under Federal Rule of Criminal Procedure 5.1(d), and defense
counsel accordingly consents on behalf of the defendant to extending the time limit for the preliminary
hearing. The parties further stipulate and agree to an extension of time for the 30-day time period of an
indictment under the Speedy Trial Act.
IT IS SO STIPULATED.
*The filing attorney certifies that he has received written authorization to file this Stipulation and
[Proposed] Order on behalf of the non-filing attorney.
Dated: October 9, 2026
JODI LINKER
Federal Public Defender
Northern District of California
/S/
DEJAN M. GANTAR
Assistant Federal Public Defender
Dated: October 9, 2026
CRAIG MISSAKIAN
United States Attorney
Northern District of California
/S/
KENNETH CHAMBERS
Assistant United States Attorney
Case 5:26-mj-70438-MAG Document 24 Filed 10/09/26 Page 2 of 3

[PROPOSED] ORDER
NGUYEN, 26-CR-70438 MAG
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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, and for good cause shown, the Court HEREBY ORDERS
that the status conference currently scheduled for October 13, 2026 be continued until December 18,
2026. For good cause shown, the Court further finds that failing to exclude the time between October
13, 2026 and December 18, 2026 would deny counsel the reasonable time necessary for effective
preparation, taking into account the exercise of due diligence, and that the ends of justice served by
excluding that time from computation under the Speedy Trial Act outweigh the best interests of the
public and the defendant in a speedy trial.
Therefore, IT IS HEREBY FURTHER ORDERED that the time between October 13, 2026 and
December 18, 2026 shall be excluded from computation under the Speedy Trial Act. 18 U.S.C. §
3161(h)(7)(A) and (B)(iv).
The Court further finds good cause exists for extending the time limits for a preliminary
hearing under Federal Rule of Criminal Procedure 5.1 and for extending the 30-day time period for an
indictment under the Speedy Trial Act. See Fed. R. Crim. P. 5.1; 18 U.S.C. § 3161(b).
IT IS SO ORDERED.
Dated: ______________
HON. NATHANAEL COUSINS
United States Chief Magistrate Judge
October 9, 2026
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