USA v. Soria-Cuevas

1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
ERIC GRANT
United States Attorney
ANTONIO J. PATACA
JUSTIN GILIO
Assistant United States Attorneys
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.
JAMES EARL MELO, Defendant.
CASE NO. 1:24-CR-00055-JLT-SKO
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
STIPULATION
1. By previous order, this matter was set for trial on February 3, 2026.
2. By this stipulation, defendant now moves to vacate the trial date as to him only and set a
change of plea hearing on February 9, 2026. The parties further agree and stipulate to exclude time
between February 3, 2026, and February 9, 2026, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The discovery associated with this case is voluminous and includes tens of
thousands of pages, including investigative reports, photographs and videos, as well as hundreds
of hours of recorded telephone conversations pursuant to wiretap orders, cellular phone
extractions, and large amounts of cellular telephone precise location data and vehicle tracker
data. All this discovery has been either produced directly to counsel, and/or made available for
Case 1:24-cr-00055-JLT-SAB Document 799 Filed 12/02/25 Page 1 of 3

2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
inspection and copying.
b) Counsel for defendant desires additional time to consult to prepare for the change
of plea hearing and conduct investigation in support of mitigation for sentencing.
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.
4. 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 February 3, 2026, to February 9, 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.
5. 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: December 2, 2025 ERIC GRANT
United States Attorney
/s/ ANTONIO J. PATACA
ANTONIO J. PATACA
Assistant United States Attorney
Case 1:24-cr-00055-JLT-SAB Document 799 Filed 12/02/25 Page 2 of 3

3
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
30
Dated: December 2, 2025 /s/ DANIEL L. HARRALSON
DANIEL L. HARRALSON
Counsel for Defendant
JAMES EARL MELO
ORDER
IT IS SO FOUND.
IT IS SO ORDERED.
Dated: December 2, 2025
Case 1:24-cr-00055-JLT-SAB Document 799 Filed 12/02/25 Page 3 of 3