USA v. Vargas-Guillen

1	STIPULATION REGARDING E XCLUDABLE T IME
PERIODS U NDER SPEEDY T RIAL A CT
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ERIC GRANT
United States Attorney
DAVID W. SPENCER
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.
JOSE CARLOS VARGAS GUILLEN,
Defendant.
CASE NO. 2:26-CR-00174-TLN
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
DATE: October 15, 2026
TIME: 9:30 a.m.
COURT: Hon. Troy L. Nunley
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. 	By previous order, this matter was set for status on October 15, 2026.
2. 	By this stipulation, defendant now moves to continue the status conference until January
21, 2027, and to exclude time between October 15, 2026, and January 21, 2027, under Local Code T4.
3. 	The parties agree and stipulate, and request that the Court find the following:
a) 	The government has represented that the discovery associated with this case
includes approximately 248 pages of reports, search warrants, photographs, and other evidence.
All of this discovery has been either produced directly to counsel and/or made available for
inspection and copying.
Case 2:26-cr-00174-TLN Document 20 Filed 10/14/26 Page 1 of 3

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b) 	Counsel for defendant desires additional time to review the discovery, conduct
factual investigation and legal research, consult with her client regarding his options for
responding to the charges, and otherwise prepare for trial.
c) 	Counsel for defendant believes that failure to grant the above-requested
continuance would deny her 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.
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 October 15, 2026 to January 21,
2027, 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.
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 13, 2026 	ERIC GRANT
United States Attorney
/s/ DAVID W. SPENCER
DAVID W. SPENCER
Assistant United States Attorney
Case 2:26-cr-00174-TLN Document 20 Filed 10/14/26 Page 2 of 3

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Dated: October 13, 2026 	/s/ NOA OREN
NOA OREN
Counsel for Defendant
JOSE CARLOS VARGAS
GUILLEN
ORDER
IT IS SO FOUND AND ORDERED.
Dated: October 13, 2026
Case 2:26-cr-00174-TLN Document 20 Filed 10/14/26 Page 3 of 3