2:22-cr-00147•USA v. Labuda, et al
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1 STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT 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 30 ERIC GRANT United States Attorney JAMES R. CONOLLY 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. SARAH ANDERSON, FABIAN GOMEZ, WILLIAM OWEN, JOALEEN ROGERS, Defendants. CASE NO. 2:22-CR-147-WBS STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT; ORDER DATE: October 27, 2025 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. This case is set for a status conference on October 27, 2025. 2. By this stipulation, defendants1 now move to continue the status conference until January 12, 2026 at 10:00 a.m., and to exclude time between October 27, 2025, and January 12, 2026, under 18 U.S.C. § 3161(h)(7)(A), B(iv) [Local Code T4]. 1 Defendants Wendy Labuda and Epifanio Ramirez do not join in this stipulation. Wendy Labuda entered a guilty plea on July 21, 2025 (ECF No. 181). Epifanio Ramirez entered an open plea to three of the four counts with which he is charged. ECF No. 195. The Court set a trial date of December 9, 2025, for the remaining count, for Mr. Ramirez only. ECF No. 198 Case 2:22-cr-00147-WBS Document 204 Filed 10/28/25 Page 1 of 3
2 STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT 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 30 3. The parties agree and stipulate, and request that the Court find the following: a) The government has produced discovery in this matter, consisting of over 1,300 pages of investigative reports and photographs, including arrest reports, DEA reports, and other supporting documents. The government has also made available to the defense for viewing at the U.S. Attorney’s Office, by appointment, hours of video surveillance evidence for multiple controlled drug buys in the underlying investigation. b) Defense counsel desire additional time to conduct investigation into the charges, the alleged roles of their respective clients, and to review discovery in this case, including watching the video evidence the government has made available. Defense counsel will need additional time to discuss potential resolutions with their clients, prepare pretrial motions, and otherwise prepare for trial. c) In addition, defense counsel Philippa Lauben has recently substituted in as counsel for Sarah Anderson. She will need additional time to get up to speed on this matter and to discuss the case with her client. d) Counsel for defendants believe that failure to grant the above-requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. e) The government does not object to the continuance. f) 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. g) 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 27, 2025 to January 12, 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 interest of the public and the defendant in a speedy trial. / / / Case 2:22-cr-00147-WBS Document 204 Filed 10/28/25 Page 2 of 3
3 STIPULATION REGARDING EXCLUDABLE TIME PERIODS UNDER SPEEDY TRIAL ACT 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 30 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 22, 2025 ERIC GRANT United States Attorney /s/ JAMES R. CONOLLY JAMES R. CONOLLY Assistant United States Attorney Dated: October 22, 2025 /s/ PHILIPPA LAUBEN PHILIPPA LAUBEN Counsel for Defendant SARAH ANDERSON Dated: October 22, 2025 /s/ DAVID D. FISCHER DAVID D. FISCHER Counsel for Defendant FABIAN GOMEZ Dated: October 22, 2025 /s/ JOHN R. MANNING JOHN R. MANNING Counsel for Defendant WILLIAM OWEN Dated: October 22, 2025 /s/ TAMARA SOLOMAN TAMARA SOLOMAN Counsel for Defendant JOALEEN ROGERS ORDER IT IS SO FOUND AND ORDERED. Dated: October 27, 2025 Case 2:22-cr-00147-WBS Document 204 Filed 10/28/25 Page 3 of 3
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