USA v. Zuniga II, et al

1	STIPULATION REGARDING E XCLUDABLE T IME
PERIODS U NDER SPEEDY T RIAL A CT
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DAVID D. FISCHER, CA SBN 224900
LAW OFFICES OF DAVID D. FISCHER, APC
5701 Lonetree Blvd Ste 311
Rocklin, CA 95765
Phone: (916) 447-8600
Fax: (916) 930-6482
E-mail: david.fischer@fischerlawoffice.com
Attorney for Defendant
YAIR ZUNIGA, II
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
RAFAEL ARAUZA
YAIR ZUNIGA, II.,
Defendants.
CASE NO. 2:24-CR-0319-WBS
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
DATE: January 25, 2027
TIME: 10:00 a.m.
COURT: Hon. William B. Shubb
This case is set for a status conference on October 19, 2026. By this stipulation, the parties
request a continuance of the status conference to January 25, 2027 at 10:00 a.m., and to exclude time
under Local Code T4, for the reasons set forth below.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, Charles Campbell, and
defendant Rafael Arauza, by and through his counsel of record Robert Forkner, and defendant Yair
Zuniga II, by and through his counsel of record, David D. Fischer, hereby stipulate as follows:
1. 	By previous order, this matter was set for status on October 19, 2026.
2. 	By this stipulation, defendants now move to continue the status conference until January
25, 2027, and to exclude time between October 19, 2027, and January 25, 2027, under Local Code T4.
3. 	The parties agree and stipulate, and request that the Court find the following:
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a) 	On May 2, 2025, the government produced discovery for this case consisting of
1350 documents and native files subject to a protective order consisting of hundreds of pages of
discovery, including numerous photographs, audio files, and audio/video discovery, as well as
police reports and criminal history documents.
b) 	Counsel for defendants desires additional time to consult with their clients, review
the current charges, conduct investigations and research related to the charges, review discovery,
consider whether to request additional discovery, prepare pretrial motions, and otherwise prepare
for trial..
c) 	Counsel for defendants needs additional time to review the discovery in this case,
to conduct independent factual investigation, to research trial and sentencing issues, to consult
with his client, and to otherwise prepare for trial.
d) 	Counsel for the defendants believes 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 19, 2026 to January 25,
2027, 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 defendants’ 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.
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.
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IT IS SO STIPULATED.
Dated: October 13, 2026 	ERIC GRANT
United States Attorney
/s/ Charles Campbell
CHARLES CAMPBELL
Assistant United States Attorney
Dated: October 13, 2026 	/s/ Robert Forkner
ROBERT L. FORKNER
Counsel for Defendant
RAFAEL ARAUZA
Dated: October 13, 2026 	/s/ David D. Fischer
DAVID D. FISCHER
Counsel for Defendant
YAIR ZUNIGA, II
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FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
Dated: October 13, 2026
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