USA v. Sanchez, et. al

STIP. AND [PROPOSED] ORDER RE PRETRIAL SCHEDULE 	1
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CRAIG H. MISSAKIAN (CABN 125202)
United States Attorney
JEFF MITCHELL (CABN 236225)
Chief, Criminal Division
AMANI S. FLOYD (CABN 301506)
ANNE C. HSIEH (CABN 288159)
Assistant United States Attorneys
60 South Market Street, Suite 1200
San Jose, California 95113
Telephone: (408) 535-5596
FAX: (408) 535-5066
Amani.Floyd@usdoj.gov
Anne.Hsieh@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.
MAXIMINO SOLORIO SANCHEZ, et al.,
Defendants.
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CASE NO. CR-24-019-PCP
STIPULATION AND [PROPOSED] ORDER
REGARDING AMENDED PRETRIAL SCHEDULE
Trial in this matter is set for January 25, 2027. 	On April 10, 2026, the Court issued a Pretrial
Order, setting dates and pretrial notice/disclosure deadlines. 	See Dkt. 540. 	The pretrial schedule was
negotiated between the parties and submitted to the Court as a stipulation and proposed order. See Dkt.
528.
After meeting and conferring, the parties respectfully ask the Court to amend the current pretrial
schedule. Trial has been set in another matter for both government counsel for December 1, 2026, and
the pretrial schedule in that case is in direct conflict with the pretrial schedule in this case. Additionally,
the parties would benefit from additional time to resolve several cases in this matter prior to the start of
pretrial notice/disclosure deadlines so that it is clearer which defendants may be proceeding to trial in
Case 5:24-cr-00019-PCP Document 593 Filed 07/22/26 Page 1 of 4

STIP. AND [PROPOSED] ORDER RE PRETRIAL SCHEDULE 	2
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January 2027. To that end, the parties submit the following proposed amended pretrial schedule:
EVENT 	DATE
Deadline for government’s disclosure of proposed Rule 404(b)
material, co-conspirator statements, and government experts 	August 14, 2026
Deadline for defendants’ Fed. R. Crim. P. 16 disclosures,
including expert disclosures
Deadline for defendants’ Fed. R. Crim. P. 12.1 and 12.2 notices
September 14, 2026
Deadline for government to provide defendants transcripts of
conversations or statements to be shown to the jury and Jencks
Act disclosures
Exchange of preliminary witness and exhibit lists
October 7, 2026
Filing of pretrial motions, including:
Motions in limine
Motions to exclude co-conspirator statements
Daubert motions or other motions directed at expert testimony
Motions to exclude or include Rule 404(b) acts
Motions directed at the accuracy of translations or transcripts of
recordings to be shown to the jury
October 21, 2026
Filing of oppositions to pretrial motions, including oppositions
to motions in limine and Daubert motions 	November 18, 2026
Filing of:
Joint pretrial conference statement
Joint proposed jury instructions
Joint proposed case-specific questions for juror questionnaire
Statement of the case
Stipulations
Witness lists
Exhibit lists and objections
Trial memorandum
Government’s proposed verdict form
December 16, 2026
Disclosure of confidential witness names 	December 23, 2026
Pretrial Conference 	January 6, 2026
Filing of final exhibit and witness lists 	January 18, 2027
Exchange of opening statement demonstratives 	January 24, 2027
Jury Trial 	January 25, 2027
IT IS SO STIPULATED.
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DATED: 	July 22, 2026 	/s/ 	__
AMANI S. FLOYD
ANNE C. HSIEH
Assistant United States Attorneys
DATED: 	July 22, 2026 	/s/
HANNAH LABAREE
Counsel for Defendant MAXIMINO SOLORIO
SANCHEZ
/s/
NICHOLAS F. REYES
Counsel for Defendant LUCIANO MALDONADO
GONZALEZ
/s/
KAREN MCCONVILLE
Counsel for Defendant JUAN CARLOS RIVERA
GASPAR
/s/
JERRY Y. FONG
Counsel for Defendant PABLO VALVERDE
URTAHDO
/s/
CARLEEN R. ARLIDGE
Counsel for Defendant FERNANDO DIAZ REYES
/s/
BRUCE FUNK
Counsel for Defendant FRANCISCO SALGADO
HERNANDEZ
/s/
RUBEN MUÑOZ
Counsel for Defendant CARLOS AGUIRRE
RIVERA
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/s/
AARON J. SHNIDER
Counsel for Defendant MANUEL CRUZ
RAMIREZ
/s/
JAMES THOMSON
Counsel for Defendant HUVER VARGAS LOPEZ
/s/
MATTHEW DIRKES
Counsel for Defendant DARIO AVILA GUZMAN
/s/
GAIL SHIFMAN
Counsel for Defendant ISMAEL MIRANDA
/s/
ROBERT WAGGENER
Counsel for Defendant SILVANO MEDINA
GUTIERREZ
/s/
ERIK BABCOCK
Counsel for Defendant JULIO LABRADO
IT IS SO ORDERED.
DATED: July __, 2026
HON. P. CASEY PITTS
United States District Judge
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