USA v. Roberts

1	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS UNDER SPEEDY TRIAL ACT
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ERIC GRANT
United States Attorney
ADRIAN T. KINSELLA
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.
MARQUESE ALVIN ROBERTS,
Defendant.
CASE NO. 2:25-CR-00269-DC
CASE NO. 2:18-CR-00018-DC
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
DATE: October 16, 2026
TIME: 9:30 a.m.
COURT: Hon. Dena Coggins
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 16, 2026. ECF No. 35. Time
has been excluded until this date. Id. The related case is set for an Admit/Deny hearing on the same
date. 2:18-CR-00018-DC, ECF No. 98.
2. By this stipulation, defendant now moves to reset the status conference to November 20,
2026, and to exclude time between October 16, 2026, and November 20, 2026, 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 CHP helicopter footage, body camera footage, reports, a forensic cellular phone
extraction, and other evidence. All of this discovery is in the process of been either produced
Case 2:25-cr-00269-DC Document 37 Filed 10/14/26 Page 1 of 4

2	STIPULATION REGARDING EXCLUDABLE TIME
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directly to counsel and/or made available for inspection and copying. Much of this discovery is
subject to a protective order. Additionally, at counsel for defendant’s request, the government
has recently provided a second plea offer.
b) Counsel for defendant desires additional time consult with her client, to review
the current charge, to conduct investigation and research related to the charge, to review and
copy discovery for this matter, to discuss potential resolutions with his client, including the
pending offer, to prepare pretrial motions, and to otherwise prepare for trial. Counsel for
defendant was recently substituted in as new counsel of record (ECF No. 94) and is still working
on reviewing the case with her client. Additionally, counsel for defendant as expressed that her
client is housed at a jail in California City, which has made visitation more difficult for her.
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 16, 2026 to November 20,
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.
//
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Case 2:25-cr-00269-DC Document 37 Filed 10/14/26 Page 2 of 4

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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 14, 2026 ERIC GRANT
United States Attorney
/s/ ADRIAN T. KINSELLA
ADRIAN T. KINSELLA
Assistant United States Attorney
Dated: October 14, 2026 /s/ TAMARA SOLOMON
TAMARA SOLOMON
Counsel for Defendant
MARQUESE ALVIN ROBERTS
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ORDER
IT IS HEREBY ORDERED, the court, having received, read and considered the parties’
stipulation filed on October 14, 2026 (Doc. No. 36), and good cause appearing therefrom, APPROVES
the parties’ stipulation. Accordingly, the Status Conference scheduled for October 16, 2026, is
VACATED and RESET for November 20, 2026 at 9:30 a.m. in Courtroom 10 before the Honorable
Dena M. Coggins. The time period between October 16, 2026 and November 20, 2026, inclusive, is
excluded from computation of time within which the trial of this case must be commenced under the
Speedy Trial Act pursuant to 18 U.S.C.§ 3161(h)(7)(A), and B(iv) [Local Code T4], as the ends of
justice served by granting the continuance outweigh the best interest of the public and the defendant’s in
a speedy trial.
IT IS FURTHER ORDERED, the Violation (Admit/Deny) Hearing in the trailing matter, 2:18-
cr-00018-DC, set for October 16, 2026, is also VACATED and RESET for November 20, 2026 at 9:30
a.m. in Courtroom 10 before the Honorable Dena M. Coggins.
IT IS SO ORDERED.
Dated: October 14, 2026	___________________________
Dena Coggins
United States District Judge
Case 2:25-cr-00269-DC Document 37 Filed 10/14/26 Page 4 of 4