USA v. Vinson

1	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS UNDER SPEEDY TRIAL ACT
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ERIC GRANT
United States Attorney
ANTONIO J. PATACA
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, CA 93721
Telephone: (559) 497-4000
Facsimile: (559) 497-4099
Attorneys for Plaintiff
United States of America
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
DARYL VINSON,
Defendants.
CASE NO. 1:25-CR-00028-KES-EPG
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
ORDER
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and
through her counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for a status conference on January 14, 2026.
2. By this stipulation, defendant now moves to continue the status conference to February
25, 2026, and to exclude time between January 14, 2026, and February 25, 2026, pursuant to 18 U.S.C.§
3161(h)(7)(A), B(iv).
3. The parties agree and stipulate, and request that the Court find the following:
a) The government provided discovery to defense counsel in accordance with the
statutory timeline. The discovery consists of law enforcement reports and surveillance footage.
Defense requests additional time to review the discovery and discuss the case with Mr. Vinson.
b) Counsel for the government is newly assigned to the case as of November 10,

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2025.
c) The government made a plea offer to the defendant on May 5, 2025. The defense
counsel requires additional time to discuss the plea offer with her client and conduct negotiations
with the recently assigned Assistant United States Attorney. The parties will be prepared to
schedule a trial date, if necessary, at the next status conference.
d) The defendant asks the Court to exclude time between January 14, 2026, and
February 25, 2026, to account for time to conduct their own investigation, discuss potential
resolution of the case via a plea agreement, and determine if this case needs to be set for trial,
taking into account the exercise of due diligence.
e) The government does not object to the continuance.
f) 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.
g) 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 14, 2026 to February 25,
2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv), because it
results from a continuance granted by the Court at defendants’ 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 dictate that additional time periods are excludable from the period within which a trial
must commence.
IT IS SO STIPULATED.
Dated: January 6, 2026 ERIC GRANT
United States Attorney
/s/ ANTONIO J. PATACA
ANTONIO J. PATACA
Assistant United States Attorney

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PERIODS UNDER SPEEDY TRIAL ACT
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Dated: January 6, 2026 /s/ BARBARA O’NEIL
BARBARA O’NEIL
Counsel for Defendant
DARYL VINSON
FINDINGS AND ORDER
For the reasons set forth in the parties’ stipulation, the status conference shall be continued until
February 25, 2026, and time will be excluded between January 14, 2026, and February 25, 2026,
pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) because the ends of justice served by taking such action
outweigh the best interest of the public and the defendant in a speedy trial.
IT IS SO ORDERED.
Dated: January 6, 2026 /s/
UNITED STATES MAGISTRATE JUDGE