USA v. Lucero-Peace et al

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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
JEFF MITCHELL (CABN 236225)
Chief, Criminal Division
NEAL C. HONG (ILBN 6309265)
Assistant United States Attorney
60 S. Market, Suite 1200
San Jose, California 95113
Telephone: (408) 535-5081
neal.hong@usdoj.gov
Attorneys for United States of America
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JONATHAN LUCERO PEACE,
Defendant.
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Case No. 26-CR-00048-1 EKL
STIPULATION TO CONTINUE STATUS
HEARING AND EXCLUDE TIME UNDER THE
SPEEDY TRIAL ACT AND [PROPOSED] ORDER
Currently, there is a status conference scheduled for April 7, 2026. Counsel for Defendant is
reviewing discovery. Counsel for Defendant requires additional time to review certain matters to
effectively prepare Defendant’s case. Accordingly, the parties respectfully request that the Court
continue the status conference scheduled for April 7, 2026, to May 26, 2026.
The parties stipulate and agree that excluding time until March 26, 2026, will allow for the
effective preparation 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 April 7, 2026, to May 26,
2026, from computation under the Speedy Trial Act outweigh the best interests of the public and
Defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
Case 5:26-cr-00048-EKL Document 42 Filed 04/03/26 Page 1 of 3

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IT IS SO STIPULATED 	CRAIG H. MISSAKIAN
United States Attorney
Dated: April 2, 2026 	/s/ Neal Hong________________
NEAL C. HONG
Assistant United States Attorney
/s/ Naomi Chung_________________
NAOMI CHUNG
Counsel for Defendant
Case 5:26-cr-00048-EKL Document 42 Filed 04/03/26 Page 2 of 3

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[PROPOSED] ORDER
Pursuant to the parties’ stipulation, and for good cause shown, the Court hereby continues the
status conference to May 26, 2026, and excludes time under the Speedy Trial Act from April 7, 2026, to
May 26, 2026. The Court finds that failing to exclude the time from April 7, 2026, to May 26, 2026,
would unreasonably deny defense counsel and the defendant 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 April 7, 2026, to May 26,
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 time from April 7, 2026, to May 26, 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. EUMI K. LEE
United States District Judge
April 3, 2026
Case 5:26-cr-00048-EKL Document 42 Filed 04/03/26 Page 3 of 3