USA v. Vera La Cruz

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CANDICE L. FIELDS
Candice Fields Law, PC
621 Capitol Mall, Suite 900
Sacramento, CA 95814
(916)414-8050
cfields@candicefieldslaw.com
Attorney for defendant
Danail Damov
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
DANAIL KONSTANTINOV DAMOV
Defendant.
CASE NO. 2:24-CR-00091-DC
STIPULATION REGARDING
EXCLUDABLE TIME PERIODS UNDER
SPEEDY TRIAL ACT; ORDER
DATE: October 16, 2026
TIME: 9:30 a.m.
COURT: Hon. Dena M. Coggins
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant
Danail Konstantinov Damov, by and through his counsel of record, hereby stipulate as follows:
This case is set for a status conference on October 16, 2026, at 9:30 a.m. before the Honorable
Dena M. Coggins.
By this stipulation, defendant now moves to continue the status conference until
December 4, 2026, and to exclude time between October 16, 2026, and December 4, 2026, under
18 U.S.C. § 3161(h)(7)(A), (B)(iv) [Local Code T4].
The parties agree and stipulate, and request that the Court find the following:
a. This case was indicted on April 18, 2024. ECF 1.
Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 1 of 4

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b. Defendant Danail Konstantinov Damov made his initial appearance and was
arraigned on May 21, 2026. He entered a plea of not guilty and demanded a jury trial. ECF 82.
c. While the government has produced discovery to the defense, certain produced
discovery requires reproduction in a usable format; that reproduction is pending.
d. Defense counsel requires additional time to review discovery, investigate the
charges and alleged conduct, consult with defendant, and prepare the defense. Defense counsel
therefore requests additional time for effective preparation, including continued discovery review
and investigation.
e. Defense counsel believes that failure to grant the requested continuance would
deny counsel the reasonable time necessary for effective preparation, taking into account the
exercise of due diligence.
f. The government does not object to the continuance.
Based on the above-stated findings, the ends of justice served by continuing the case as
requested outweigh the best interests of the public and the defendant in a speedy trial.
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 from October 16, 2026, through December 4,
2026, 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 defendant’s request on
the basis of the Court’s finding that the ends of justice served by taking such action outweigh the
best interests of the public and the defendant in a speedy trial.
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.
IT IS SO STIPULATED.
October 13, 2026 /s/ Candice L. Fields
Candice L. Fields
Counsel for Defendant
DANAIL KONSTANTINOV DAMOV
Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 2 of 4

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October 13, 2026 ERIC A. GRANT
United States Attorney
/s/ Elliot C. Wong
Assistant United States Attorney
Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 3 of 4

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ORDER
IT IS HEREBY ORDERED as to Danail Konstantinov Damov, the court, having received,
read and considered the parties’ stipulation filed on October 13, 2026 (Doc. No. 97), and good
cause appearing therefrom, APPROVES the parties’ stipulation. Accordingly, the Status
Conference scheduled for October 16, 2026, is VACATED and RESET for December 4, 2026 at
9:30 a.m. in Courtroom 10 before the Honorable Dena M. Coggins. The time period between
October 16, 2026 and December 4, 2026, inclusive, is excluded from computation of time within
which the trial of this case must be commenced under the Speedy Trial Act pursuant to 18
U.S.C.§ 3161(h)(7)(A), and B(iv) [Local Code T4], as the ends of justice served by granting the
continuance outweigh the best interest of the public and the defendant(s) in a speedy trial.
IT IS SO ORDERED.
Dated: October 13, 2026	___________________________
Dena Coggins
United States District Judge
Case 2:24-cr-00091-DC Document 99 Filed 10/13/26 Page 4 of 4