USA v. Labuda, et al

1	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS UNDER SPEEDY TRIAL ACT
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ERIC GRANT
United States Attorney
JAMES R. CONOLLY
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
UNITED STATES OF AMERICA,
Plaintiff,
v.
SARAH ANDERSON,
FABIAN GOMEZ,
WILLIAM OWEN,
JOALEEN ROGERS,
Defendants.
CASE NO. 2:22-CR-147-WBS
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
ORDER
DATE: October 27, 2025
TIME: 10:00 a.m.
COURT: Hon. William B. Shubb
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and
through defendant’s counsel of record, hereby stipulate as follows:
1. This case is set for a status conference on October 27, 2025.
2. By this stipulation, defendants1 now move to continue the status conference until
January 12, 2026 at 10:00 a.m., and to exclude time between October 27, 2025, and January 12, 2026,
under 18 U.S.C. § 3161(h)(7)(A), B(iv) [Local Code T4].
1 Defendants Wendy Labuda and Epifanio Ramirez do not join in this stipulation. Wendy
Labuda entered a guilty plea on July 21, 2025 (ECF No. 181). Epifanio Ramirez entered an open plea to
three of the four counts with which he is charged. ECF No. 195. The Court set a trial date of December
9, 2025, for the remaining count, for Mr. Ramirez only. ECF No. 198
Case 2:22-cr-00147-WBS Document 204 Filed 10/28/25 Page 1 of 3

2	STIPULATION REGARDING EXCLUDABLE TIME
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3. The parties agree and stipulate, and request that the Court find the following:
a) The government has produced discovery in this matter, consisting of over 1,300
pages of investigative reports and photographs, including arrest reports, DEA reports, and other
supporting documents. The government has also made available to the defense for viewing at the
U.S. Attorney’s Office, by appointment, hours of video surveillance evidence for multiple
controlled drug buys in the underlying investigation.
b) Defense counsel desire additional time to conduct investigation into the charges,
the alleged roles of their respective clients, and to review discovery in this case, including
watching the video evidence the government has made available. Defense counsel will need
additional time to discuss potential resolutions with their clients, prepare pretrial motions, and
otherwise prepare for trial.
c) In addition, defense counsel Philippa Lauben has recently substituted in as
counsel for Sarah Anderson. She will need additional time to get up to speed on this matter and
to discuss the case with her client.
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) 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 defendant 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 October 27, 2025 to January 12,
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.
/ / /
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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: October 22, 2025 ERIC GRANT
United States Attorney
/s/ JAMES R. CONOLLY
JAMES R. CONOLLY
Assistant United States Attorney
Dated: October 22, 2025 /s/ PHILIPPA LAUBEN
PHILIPPA LAUBEN
Counsel for Defendant
SARAH ANDERSON
Dated: October 22, 2025 /s/ DAVID D. FISCHER
DAVID D. FISCHER
Counsel for Defendant
FABIAN GOMEZ
Dated: October 22, 2025 /s/ JOHN R. MANNING
JOHN R. MANNING
Counsel for Defendant
WILLIAM OWEN
Dated: October 22, 2025 /s/ TAMARA SOLOMAN
TAMARA SOLOMAN
Counsel for Defendant
JOALEEN ROGERS
ORDER
IT IS SO FOUND AND ORDERED.
Dated: October 27, 2025
Case 2:22-cr-00147-WBS Document 204 Filed 10/28/25 Page 3 of 3