2:24-cr-00091•USA v. Vera La Cruz
Gesamter Gesetzestext
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 1 CANDICE L. FIELDS Candice Fields Law, PC 621 Capitol Mall, Suite 900 Sacramento, CA 95814 (916)414-8050 cfields@candicefieldslaw.com Attorney for defendant Danail Damov UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. DANAIL KONSTANTINOV DAMOV Defendant. CASE NO. 2:24-CR-00091-DC STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER DATE: October 16, 2026 TIME: 9:30 a.m. COURT: Hon. Dena M. Coggins STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant Danail Konstantinov Damov, by and through his counsel of record, hereby stipulate as follows: This case is set for a status conference on October 16, 2026, at 9:30 a.m. before the Honorable Dena M. Coggins. By this stipulation, defendant now moves to continue the status conference until December 4, 2026, and to exclude time between October 16, 2026, and December 4, 2026, under 18 U.S.C. § 3161(h)(7)(A), (B)(iv) [Local Code T4]. The parties agree and stipulate, and request that the Court find the following: a. This case was indicted on April 18, 2024. ECF 1. Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 1 of 4
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 2 b. Defendant Danail Konstantinov Damov made his initial appearance and was arraigned on May 21, 2026. He entered a plea of not guilty and demanded a jury trial. ECF 82. c. While the government has produced discovery to the defense, certain produced discovery requires reproduction in a usable format; that reproduction is pending. d. Defense counsel requires additional time to review discovery, investigate the charges and alleged conduct, consult with defendant, and prepare the defense. Defense counsel therefore requests additional time for effective preparation, including continued discovery review and investigation. e. Defense counsel believes that failure to grant the requested continuance would deny counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. f. The government does not object to the continuance. Based on the above-stated findings, the ends of justice served by continuing the case as requested outweigh the best interests of the public and the defendant in a speedy trial. 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 from October 16, 2026, through December 4, 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 interests of the public and the defendant in a speedy trial. 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. October 13, 2026 /s/ Candice L. Fields Candice L. Fields Counsel for Defendant DANAIL KONSTANTINOV DAMOV Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 2 of 4
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 3 October 13, 2026 ERIC A. GRANT United States Attorney /s/ Elliot C. Wong Assistant United States Attorney Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 3 of 4
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 4 ORDER IT IS HEREBY ORDERED as to Danail Konstantinov Damov, the court, having received, read and considered the parties’ stipulation filed on October 13, 2026 (Doc. No. 97), and good cause appearing therefrom, APPROVES the parties’ stipulation. Accordingly, the Status Conference scheduled for October 16, 2026, is VACATED and RESET for December 4, 2026 at 9:30 a.m. in Courtroom 10 before the Honorable Dena M. Coggins. The time period between October 16, 2026 and December 4, 2026, inclusive, is excluded from computation of time within which the trial of this case must be commenced under the Speedy Trial Act pursuant to 18 U.S.C.§ 3161(h)(7)(A), and B(iv) [Local Code T4], as the ends of justice served by granting the continuance outweigh the best interest of the public and the defendant(s) in a speedy trial. IT IS SO ORDERED. Dated: October 13, 2026 ___________________________ Dena Coggins United States District Judge Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 4 of 4
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