2:25-cr-00166•USA v. Nolan
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-1- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 United States v. Nolan. 25-CR-166-DJC Stipulation and Order to Continue Status Conference and Exclude Time Kyle R. Knapp, SBN 166597 Attorney at Law 916 2nd Street 2nd Floor Sacramento, CA 916814 916-441-4717 Fax:916-441-4299 kyleknapp@sbcglobal.net Attorney for Defendant Sonny Nolan IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, vs. SONNY NOLAN, Defendants. ) ) ) ) ) ) ) ) ) ) Case No. 25-CR-166-DJC STIPULATION AND ORDER TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME Date: December 4, 2025 Time: 9:00 a.m. Judge: Hon. Daniel J. Calabretta IT IS HEREBY STIPULATED and agreed by and between United States Attorney Eric Grant, through Assistant United States Attorney, Alex Cardenas, counsel for Plaintiff and Kyle Knapp, counsel for Sonny Nolan that the status hearing currently set for December 4, 2025, at 9:00 be continued to January 15, 2026, at 9:00 a.m. The parties specifically stipulate as follows: 1. By previous order, this matter was set for a status on December 4, 2025, at 9:00 a.m. 2. By stipulation, Mr. Nolan now moves to continue the status conference to January 15, 2026, at 9:00 a.m. 3. Counsel for the defendant was recently appointed and a thumb drive containing the discovery in this matter was produced on October 15, 2025. 4. Mr. Nolan requires additional time to review the discovery, investigate and
-2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 United States v. Nolan. 25-CR-166-DJC Stipulation and Order to Continue Status Conference and Exclude Time research possible defenses, research potential pretrial motions, and explore potential resolutions to the case, and otherwise prepare for trial. 5. Mr. Nolan believes that failure to grant the requested continuance would deny them the reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 6. The government does not object to the requested continuance. 7. 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 December 4, 2025 and January 15, 2026, 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. Nolan in a speedy trial. Respectfully submitted, Date: December 1, 2025 /s/ Kyle Knapp Kyle Knapp Attorney for Mr. Nolan // Date: December 1, 2025 ERIC GRANT United States Attorney /s/ Alex Cardenas Alex Cardenas Assistant United States Attorney Attorneys for Plaintiff
-3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 United States v. Nolan. 25-CR-166-DJC Stipulation and Order to Continue Status Conference and Exclude Time O R D E R The Court, having received and considered the parties’ stipulation, and good cause appearing therefrom, adopts the parties’ stipulation in its entirety as its order. IT IS SO ORDERED. Dated: December 1, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE
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