USA v. Tolentino et al

1	S TIPULATION REGARDING EXCLUDABLE TIME
P ERIODS U NDER S PEEDY TRIAL A CT
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ERIC GRANT
United States Attorney
ROBERT C. ABENDROTH
NICOLE M. VANEK
Assistant United States Attorneys
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
UNITED STATES OF AMERICA,
Plaintiff,
v.
LLOYD LISTER,
ELMER MONTIEL-ROMERO,
LEON JAMES WHITELEY,
LYLE COOPER,
JUAN MUNOZ-GUZMAN,
COY MOBLEY,
JESSICA PACK,
BRANDI EMERSON,
BRIAN SEDGWICK, and
VANESSA FLORES-GOMEZ,
Defendants.
CASE NO. 2:25-CR-00247-DJC
STIPULATION TO CONTINUE STATUS
CONFERENCE AND TO EXCLUDE TIME
PERIODS UNDER THE SPEEDY TRIAL ACT
AND ORDER
STIPULATION
1. 	By previous order, this matter was set for status on January 8, 2026.
2. 	By this stipulation, the parties now move to continue the status conference until April 16,
2026, and to exclude time between January 8, 2026, and April 16, 2026, under Local Codes T2 and T4.
3. 	The parties agree and stipulate, and request that the Court find the following:
a) 	The Defendants appeared in the Eastern District of California on the indictment
and initial discovery has been sent to counsel for the Defendants. The government intends to

2	S TIPULATION REGARDING EXCLUDABLE TIME
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send additional discovery in January 2026 which will be sent to defense counsel pursuant to a
Protective Order entered by the Court on December 18, 2025. Counsel for the government and
the defendants require additional time to coordinate the transmission of discovery pursuant to the
Protective Order.
b) 	The discovery in this matter is quite voluminous consisting of electronic data and
materials collected during Court-authorized interception of wire and electronic communications.
The discovery consists of multiple gigabytes of data. Given the amount of discovery and the
number of defendants, this case is unusually complex such that setting trial within the timeframe
outlined in the Speedy Trial Act would be unreasonable.
c) 	Counsel for defendants will require additional time to review the discovery
materials and charges, conduct investigation, conduct research related to the charges, to assess
the viability of any pretrial motions, and arrange for in-person visits to discuss potential
resolutions with their clients.
d) 	Counsel for defendants believe that failure to grant the above-requested
continuance would deny them the reasonable time necessary for effective preparation, taking into
account the exercise of due diligence.
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 defendants 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 January 8, 2026 to April 16, 2026,
inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), (B)(ii) and (iv) [Local
Codes T2 and T4] because it results from a continuance granted by the Court at the parties’
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.
/ / /
/ / /

3	S TIPULATION REGARDING EXCLUDABLE TIME
P ERIODS U NDER S PEEDY TRIAL A CT
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4. 	Nothing in this stipulation and order shall preclude a finding that other provisions of the
Speedy Trial Act warrant time periods excludable from the period within which a trial must commence.
IT IS SO STIPULATED.
Respectfully Submitted,
Dated: January 2, 2026
By:
ERIC GRANT
United States Attorney
/s/ ROBERT ABENDROTH
ROBERT ABENDROTH
Assistant United States Attorney
Dated: January 2, 2026 	/s/ F. PHILLIP COZENS
F. PHILLIP COZENS
Counsel for Defendant
LLOYD LISTER
Dated: January 2, 2026 	/s/ JAYA C. GUPTA
JAYA C. GUPTA
Counsel for Defendant
ELMBER MONTIEL-ROMERO
Dated: January 2, 2026 	/s/ MICHAEL LONG
MICHAEL LONG
Counsel for Defendant
LEON JAMES WHITELEY
Dated: January 2, 2026 	/s/ PETER JONES
PETER JONES
Counsel for Defendant
LYLE COOPER
Dated: January 2, 2026 	/s/ CLEMENTE JIMENEZ
CLEMENTE JIMENEZ
Counsel for Defendant
JUAN MUNOZ-GUZMAN
Dated: January 2, 2026 	/s/ REBECCA LEVY
REBECCA LEVY
Counsel for Defendant
COY MOBLEY

4	S TIPULATION REGARDING EXCLUDABLE TIME
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Dated: January 2, 2026 	/s/ ANA BOTELLO
ANA BOTELLO
Counsel for Defendant
JESSICA PACK
Dated: January 2, 2026 	/s/ ANTHONY CAPOZZI
ANTHONY CAPOZZI
Counsel for Defendant
BRANDI EMERSON
Dated: January 2, 2026 	/s/ OLAF HEDBERG
OLAF HEDBERG
Counsel for Defendant
BRIAN SEDGWICK
Dated: January 2, 2026 	/s/ ERIC KERSTEN
ERIC KERSTEN
Counsel for Defendant
VANESSA FLORES-GOMEZ
ORDER
IT IS SO FOUND AND ORDERED this 5 th day of January, 2026.
/s/ Daniel J. Calabretta
THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE