USA v. Paco et al

1	STIPULATION REGARDING E XCLUDABLE T IME
PERIODS U NDER SPEEDY T RIAL A CT
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ERIC GRANT
United States Attorney
DAVID W. SPENCER
Assistant United States Attorney
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
STIPULATION
1. 	This matter was set for status conference before the Honorable William B. Shubb on
October 13, 2026. Time has been excluded through and including October 13, 2026.
2. 	By this stipulation, the parties request to continue the status conference to November 30,
2026, at 10:00 a.m., and to exclude time between October 13, 2026, and November 30, 2026, under
Local Code T4.
3. 	The parties agree and stipulate, and request that the Court find the following:
a) 	The government has represented that the discovery associated with this case
includes investigative reports and related documents in electronic form including over 4,698
pages of documents, numerous photographs, lab reports, criminal history reports, multiple video
and audio recordings, and other material. All of this discovery has been either produced directly
to counsel and/or made available for inspection.
UNITED STATES OF AMERICA,
Plaintiff,
v.
JIOVANNI ELEAZAR PACO,
Defendant.
CASE NO. 2:23-CR-214-WBS
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
DATE: October 13, 2026
TIME: 9:00 a.m.
COURT: Hon. William B. Shubb

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b) 	Counsel for defendant desires additional time to consult with his client, review the
charges, conduct investigation and research related to the charges, review the discovery, discuss
potential resolutions with his client, prepare pretrial motions, and otherwise prepare for trial.
c) 	Counsel for defendant believes that failure to grant the above-requested
continuance would deny him the reasonable time necessary for effective preparation, taking into
account the exercise of due diligence.
d) 	The government does not object to the continuance.
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 defendant 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 October 13, 2026 to November 30,
2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code
T4] because it results from a continuance granted by the Court at defendant’s 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.
Respectfully Submitted,
Dated: October 8, 2026
By:
ERIC GRANT
United States Attorney
/s/ DAVID W. SPENCER
DAVID W. SPENCER
Assistant United States Attorney
Dated: October 8, 2026 	/s/ MICHAEL E. HANSEN
MICHAEL E. HANSEN
Counsel for Defendant
Jiovanni Eleazar Paco

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PERIODS U NDER SPEEDY T RIAL A CT
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ORDER
IT IS SO FOUND AND ORDERED.
Dated: October 8, 2026