USA v. Rubio

1	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS U NDER SPEEDY TRIAL A CT
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U NITED STATES V. R UBIO
ERIC GRANT
United States Attorney
JUSTIN L. LEE
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: (916) 554-2700
Attorneys for Plaintiff
United States of America
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
MARCUS ANTHONY RUBIO,
Defendant.
CASE NO. 2:26-CR-00107-WBS
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL
ACT; FINDINGS AND ORDER
DATE: October 13, 2026
TIME: 10:00 a.m.
COURT: Hon. William B. Shubb
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 13, 2026.
2. 	By this stipulation, the defendant now moves to continue the status
conference until January 11, 2027, and to exclude time between October 13, 2026, and
January 11, 2027, under Local Code T4.
3. 	The parties agree and stipulate, and request that the Court find the
following:
a) 	The discovery associated with this case includes police reports and
chemical analysis reports related to undercover drug transactions. All of this
discovery has been produced directly to counsel.

2	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS U NDER SPEEDY TRIAL A CT
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U NITED STATES V. R UBIO
b) 	Counsel for defendant desires additional time meet with his client,
review the discovery, conduct defense investigation, and otherwise prepare for trial.
Specifically, defense counsel needs additional time to review discovery produced by
the United States on September 25, 2026.
c) 	Counsel for defendant believes that failure to grant the above-
requested continuance would deny him 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 13, 2026 to January 11, 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.
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3	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS U NDER SPEEDY TRIAL A CT
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U NITED STATES V. R UBIO
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 7, 2026 	ERIC GRANT
United States Attorney
/s/ JUSTIN L. LEE
JUSTIN L. LEE
Assistant United States Attorney
Dated: October 7, 2026 	/s/ MICHAEL HANSEN
MICHAEL HANSEN
Counsel for Defendant
MARCUS ANTHONY RUBIO
ORDER
IT IS SO FOUND AND ORDERED.
Dated: October 8, 2026