USA v. Mays et al

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ERIC GRANT
United States Attorney
CODY S. CHAPPLE
STEPHANIE M. STOKMAN
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.
ANDREW RORIGUEZ, and
ANDREW MADRID,
Defendants.
CASE NO. 1:23-CR-00102-TLN-BAM
STIPULATION TO CONTINUE STATUS
CONFERENCE AND EXCLUDE TIME; AND
ORDER
The parties stipulate as follows:
1. A federal grand jury indicted seven defendants on August 31, 2023, charging them with
seventeen drug and gun related counts in a superseding indictment. Of those seven defendants, only
defendants Andrew Rodriguez and Andrew Madrid remain in this case. Defendant Rodriguez is detained,
and defendant Madrid is out of custody. Presently, a status conference is set on November 12, 2025, with
time excluded to that date.
2. On July 5, 2023, the government produced initial discovery and has produced supplemental
discovery.
3. The Government extended plea offers to the remaining defendants. Neither defendant
accepted the plea offer.
4. On August 12, 2025, Defendant Rodriguez’s attorney withdrew, and attorney John Garland

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filed a notice of appearance. ECF 246. The Court continued the September 10, 2025, status conference to
November 12, 2025, to allow Mr. Garland time to review discovery. No trial date is set.
5. Now, the parties have met and conferred and agreed to continue the status conference from
November 12, 2025, to January 14, 2026, to further provide defendants with reasonable time necessary
for effective preparation, so that the defendants can review the discovery, and for defendants to consider
a pre-trial resolution of the case.
6. The parties understand that they will appear at the next status conference to set this case
for trial if no resolution has been made by then.
7. The parties agree that the interests of justice served by granting this continuance outweigh
the best interests of the public and the defendant in a speedy trial. The parties also agree that the period
from November 12, 2025, through January 14, 2026, should be excluded. Fed. R. Crim. P. 17.1; 18 U.S.C.
§ 3161(h)(7)(A) and (h)(7)(B)(iv).
IT IS SO STIPULATED.
Dated: November 6, 2025 ERIC GRANT
United States Attorney
/s/ Cody Chapple
Cody Chapple
Stephanie M. Stokman
Assistant United States Attorney
Dated: November 6, 2025 /s/ Robert Conrad Lamanuzzi
Robert Conrad Lamanuzzi
Law Offices of Robert C Lamanuzzi
Counsel for ANDEW MADRID
Dated: November 6, 2025 /s/ John Frederick Garland
John Frederick Garland
Law Office of John Garland
Counsel for ANDREW RODRIGUEZ

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ORDER
The Court has read and considered the parties’ stipulation to further continue the status conference
and exclude time. The Court finds there is good cause for the continuance so as to allow the defendant
reasonable time to complete his review of the discovery and fully consider a pre-trial resolution of the
case. The Court also finds that the interests of justice served by granting the continuance outweigh the
interests of the public and the defendant in a speedy trial.
If the parties do not resolve the case in advance of the next status conference, they shall be prepared
to set a trial date at the status conference hearing.
Therefore, for good cause shown:
1. The status conference is continued from November 12, 2025, until January 14, 2026, at
1:00 p.m. before Magistrate Judge Barbara A. McAuliffe; and
2. The period from November 12, 2025, through January 14, 2026, shall be excluded pursuant
to Fed. R. Crim. P. 17.1; 18 U.S.C. § 3161(h)(7)(A) and (h)(7)(B)(iv).
IT IS SO ORDERED.
Dated: November 6, 2025 /s/ Barbara A. McAuliffe _
UNITED STATES MAGISTRATE JUDGE