USA v. Done Global, Inc et al

STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER 	v. 9/18/2025
Case No. 25-CR-00432 CRB 	1
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
JEFF MITCHELL (CABN 236225)
Chief, Criminal Division
LORINDA LARYEA (DCBN 99769)
Chief, Fraud Section
JIL SIMON (DCBN 1030206)
Trial Attorney, Fraud Section
SANDOR A. CALLAHAN (CABN 318200)
Trial Attorney, Fraud Section
U.S. Department of Justice, Fraud Section
1400 New York Avenue NW
Washington, DC 20005
Telephone: 202-514-2000
Jil.Simon@usdoj.gov
Sandor.Callahan2@usdoj.gov
KRISTINA GREEN (NYBN 5226204)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, CA 94102-3495
Telephone: (415) 436-7200
Kristina.Green@usdoj.gov
Attorneys for United States of America
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
DONE GLOBAL, INC. and
MINDFUL MENTAL WELLNESS P.A.,
Defendants.
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NO. 25-CR-00432 CRB
STIPULATION TO CONTINUE STATUS
CONFERENCE TO MARCH 25, 2026 AND
EXCLUDE TIME FROM JANUARY 28, 2026 TO
MARCH 25, 2026, AND [PROPOSED] ORDER
A status conference in the above-referenced matter is set for February 18, 2026. It is hereby
Case 3:25-cr-00432-CRB Document 17 Filed 02/12/26 Page 1 of 3

STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER 	v. 9/18/2025
Case No. 25-CR-00432 CRB 	2
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stipulated by and between counsel for the United States and counsel for the defendants Done Global and
Mindful Mental Wellness that this status conference be continued to March 25, 2026 at 1:30 p.m. It is
further stipulated by and between the parties that time be excluded under the Speedy Trial Act from
January 28, 2026 through March 25, 2026.
The parties agree that the status conference be continued due to unavailability of defense counsel
on February 18, 2026 and to allow for continued preparation. The government and counsel for the
defendants also agree that time be excluded under the Speedy Trial Act so that defense counsel may
continue to prepare, including by reviewing discovery, and to allow for the continuity of counsel. The
parties are currently negotiating a protective order. Once the protective order has been filed, discovery
will be produced shortly thereafter. For this reason, the parties stipulate and agree that excluding time
until March 25, 2026, will allow for the effective preparation of counsel and continuity of counsel. See
18 U.S.C. § 3161(h)(7)(B)(iv). The parties further stipulate and agree that the ends of justice served by
excluding the time from January 28, 2026 through March 25, 2026, from computation under the Speedy
Trial Act outweigh the best interests of the public and the defendant in a speedy trial. 18 U.S.C. §
3161(h)(7)(A), (B)(iv).
The undersigned Assistant United States Attorney certifies that she has obtained approval from
counsel for the defendants to file this stipulation and proposed order.
IT IS SO STIPULATED.
DATED: February 10, 2026 	/s/
KRISTINA GREEN
Assistant United States Attorney
DATED: February 10, 2026 	/s/
CHRISTOPHER STESKAL
BENJAMIN KINGSLEY
Counsel for Defendant Done Global
DATED: February 10, 2026 	/s/
TED W. CASSMAN
RAPHAEL M. GOLDMAN
Counsel for Defendant MMW
Case 3:25-cr-00432-CRB Document 17 Filed 02/12/26 Page 2 of 3

STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER 	v. 9/18/2025
Case No. 25-CR-00432 CRB 	3
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[PROPOSED] ORDER
Based upon the facts set forth in the stipulation of the parties and for good cause shown, the
Court orders that the status conference in this matter be continued to March 25, 2026 at 1:30 p.m., and
finds that failing to exclude the time from January 28, 2026, through March 25, 2026, would
unreasonably deny defense counsel and the defendant continuity of counsel and the reasonable time
necessary for effective preparation, taking into account the exercise of due diligence. 18 U.S.C. §
3161(h)(7)(B)(iv). The Court further finds that the ends of justice served by excluding the time from
January 28, 2026, to March 25, 2026, from computation under the Speedy Trial Act outweigh the best
interests of the public and the defendant in a speedy trial. Therefore, and with the consent of the parties,
IT IS HEREBY ORDERED that the status conference be continued to March 25, 2026 and that the time
from January 28, 2026, through March 25, 2026, shall be excluded from computation under the Speedy
Trial Act. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
IT IS SO ORDERED.
DATED: 	___________________________
HON. CHARLES R. BREYER
United States District Judge
February 12, 2026
Case 3:25-cr-00432-CRB Document 17 Filed 02/12/26 Page 3 of 3