USA v. Ararao

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United States v. Ararao,
2:25-cr-00276-JAM
Third Stipulation and Order to Continue
Status Hearing and Exclude Time
HEATHER E. WILLIAMS, SBN 122664
Federal Defender
HOOTAN BAIGMOHAMMADI, SBN 279105
Assistant Federal Defender
Designated Counsel for Service
801 I Street, Third Floor
Sacramento, CA 95814
T: (916) 498-5700
F: (916) 498-5710
Attorneys for Defendant
Mr. Ararao
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
vs.
BRODERICK ARARAO,
Defendant.
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Case No. 2:25-cr-00276-JAM
THIRD STIPULATION AND ORDER TO
CONTINUE STATUS CONFERENCE AND
EXCLUDE TIME
Date: October 27, 2026
Time: 9:00 a.m.
Judge: Hon. John A. Mendez
IT IS HEREBY STIPULATED and agreed by and between United States Attorney Eric
Grant, through Assistant United States Attorney Justin Lee, counsel for Plaintiff, and Federal
Defender Heather Williams, through Assistant Federal Defender Hootan Baigmohammadi,
counsel for Defendant Broderick Ararao, that the previously scheduled Status Hearing set for
October 27, 2026, be continued to January 26, 2027, at 9:00 a.m.
The parties specifically stipulate as follows:
1. 	The government has produced 403 pages and roughly 80 audio/video files in
discovery.
2. 	Mr. Ararao moves to continue the Status Conference for compelling reasons. He
is facing a mandatory minimum 25-year prison sentence. Defense counsel is
working through discovery and investigating the case.
3. 	Mr. Ararao believes that failure to grant his motion would deny him the
Case 2:25-cr-00276-JAM Document 23 Filed 10/14/26 Page 1 of 3

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United States v. Ararao,
2:25-cr-00276-JAM
Third Stipulation and Order to Continue
Status Hearing and Exclude Time
reasonable time necessary for effective preparation, taking into account the
exercise of due diligence.
4. 	The government does not object to Mr. Ararao’s motion.
5. 	For the purpose of computing time under 18 U.S.C. § 3161 et seq. (Speedy Trial
Act), the parties request that the time period between October 27, 2026 and
January 26, 2027, inclusive, be deemed excludable pursuant to 18 U.S.C. §
3161(h)(7)(B)(iv) (Local Code T4), because it would result from a continuance
granted by the Court at the defense’s request, based on a finding that the ends of
justice served by granting the continuance outweighs the best interest of the
public and Mr. Ararao in a speedy trial.
Respectfully submitted,
HEATHER E. WILLIAMS
Federal Defender
Date: October 13, 2026 	/s/ Hootan Baigmohammadi
HOOTAN BAIGMOHAMMADI
Assistant Federal Defender
Attorneys for Defendant
Mr. Ararao
Date: October 13, 2026 	ERIC GRANT
United States Attorney
/s/ Justin Lee
JUSTIN LEE
Assistant United States Attorney
Attorneys for Plaintiff
Case 2:25-cr-00276-JAM Document 23 Filed 10/14/26 Page 2 of 3

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United States v. Ararao,
2:25-cr-00276-JAM
Third Stipulation and Order to Continue
Status Hearing and Exclude Time
O R D E R
Based on the third stipulation of the parties, the October 27, 2026 status conference is
CONTINUED to January 26, 2027, at 9:00 a.m. Time is EXCLUDED as described in the
parties’ Stipulation.
IT IS SO ORDERED.
Dated: October 13, 2026
Case 2:25-cr-00276-JAM Document 23 Filed 10/14/26 Page 3 of 3