USA v. Lucero-Peace et al

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Stipulation to Continue Status Hearing and Proposed Order, Case No. 26-cr-00048-EKL
Matthew M. Yelovich (SBN 351330)
Cleary Gottlieb Steen & Hamilton LLP
1841 Page Mill Road, Suite 250
Palo Alto, CA 94304
(650) 815-4100
Email: myelovich@cgsh.com
Attorney for Defendant
JULIO JOVAN VASQUEZ-OCHOA
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiffs,
v.
JULIO JOVAN VASQUEZ-OCHOA,
Defendant.
Case No. 26-cr-00048-EKL
STIPULATION TO CONTINUE
STATUS HEARING AND
[PROPOSED] ORDER
Currently, there is a status conference scheduled for May 26, 2026. Counsel for
Defendant is evaluating and consulting with Defendant regarding legal strategy in connection
with preparing Defendant’s case. Accordingly, the parties respectfully request that the Court
continue the status conference scheduled for May 26, 2026, to August 25, 2026.1
The parties stipulate and agree that excluding time until August 25, 2026, will allow for
effective preparation and continuity of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv). The parties
further stipulate and agree that the ends of justice served by excluding the time from May 26,
1 Undersigned counsel attests that each of the other signatories have concurred in the filing of the
document.
Case 5:26-cr-00048-EKL Document 53 Filed 05/22/26 Page 1 of 3

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Stipulation to Continue Status Hearing and Proposed Order, Case No. 26-cr-00048-EKL
2026, to August 25, 2026, from computation under the Speedy Trial Act outweigh the best
interests of the public and Defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
Respectfully submitted,
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: May 22, 2026 	/s/ Matthew M. Yelovich
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: May 22, 2026 	/s/ Neal Hong________
NEAL HONG
Assistant United States Attorney
Case 5:26-cr-00048-EKL Document 53 Filed 05/22/26 Page 2 of 3

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Stipulation to Continue Status Hearing and Proposed Order, Case No. 26-cr-00048-EKL
[PROPOSED ORDER]
Pursuant to the parties’ stipulation, and for good cause shown, the Court hereby continues
the status conference to August 25, 2026, and excludes time under the Speedy Trial Act from
May 26, 2026, to August 25, 2026. The Court finds that failing to exclude the time from May
26, 2026, to August 25, 2026, would unreasonably deny defense counsel and the defendant the
reasonable time necessary for effective preparation, taking into account the exercise of due
diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The Court further finds that the ends of justice served
by excluding the time from May 26, 2026, to August 25, 2026, from computation under the
Speedy Trial Act outweigh the best interests of the public and the defendant in a speedy trial.
Therefore, and with the consent of the parties, IT IS HEREBY ORDERED that the time from
May 26, 2026, to August 25, 2026, shall be excluded from computation under the Speedy Trial
Act. 18 U.S.C. § 3161(h)(7)(A), (B)(iv).
PURSUANT TO STIPULATION IT IS SO ORDERED.
Dated: __________________
_________________________
HON. EUMI K. LEE
United States District Judge
May 22, 2026
Case 5:26-cr-00048-EKL Document 53 Filed 05/22/26 Page 3 of 3