USA v. Beall

1	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS UNDER SPEEDY TRIAL ACT
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ERIC GRANT
United States Attorney
ERIN CORNELL
Assistant United States Attorney
501 I Street, Suite 10-100
Sacramento, CA 95814
Telephone: (916) 554-2700
Facsimile: (916) 554-2900
Attorneys for Plaintiff
United States of America
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
JULIAN BEALL,
Defendant.
CASE NO. 2:26-CR-00123 DAD
STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
FINDINGS AND ORDER
DATE: October 19, 2026
TIME: 9:30 a.m.
COURT: Hon. Dale A. Drozd
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and
through defendant’s counsel of record, hereby stipulate as follows:
1. By previous order, this matter was set for status on October 19, 2026.
2. By this stipulation, defendant now moves to continue this case until November 9, 2026,
for a change of plea or trial setting, and to exclude time between October 19, 2026, and November 9,
2026, under Local Code T4.
3. The parties agree and stipulate, and request that the Court find the following:
a) The government has represented that the discovery associated with this case
includes investigative reports, lab reports, search warrant documents, photographs, and body
worn camera videos. All of this discovery has been either produced directly to counsel and/or
made available for inspection and copying.
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b) Counsel for defendant desires additional time to review discovery, conduct
investigation, consult with his client, and otherwise prepare for trial.
c) Counsel for defendant believes that failure to grant the above-requested
continuance would deny him the reasonable time necessary for effective preparation, taking into
account the exercise of due diligence.
d) The government does not object to the continuance.
e) 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.
f) 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 November 9,
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
interest of the public and the defendant in a speedy trial.
4. The government states that as of September 3, 2026, all discovery has been produced to
defendant’s counsel. On July 23, 2026, the government provided a plea offer to defendant’s counsel.
This plea offer will expire on November 9, 2026, the date of the requested change of plea/trial setting.
5. 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.
Dated: October 14, 2026 ERIC GRANT
United States Attorney
/s/ Erin Cornell
Erin Cornell
Assistant United States Attorney
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3	STIPULATION REGARDING EXCLUDABLE TIME
PERIODS UNDER SPEEDY TRIAL ACT
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Dated: October 14, 2026 /s/ Mark Reichel
Mark Reichel
Counsel for Defendant
Julian Beall
ORDER
Pursuant to the stipulation of the parties and good cause appearing, the status conference
previously scheduled in this case for October 19, 2026 is vacated and the case is now scheduled for
November 9, 2026, at 9:30 a.m. for a change of plea or trial setting, and time is excluded between
October 19, 2026, and November 9, 2026, under Local Code T4.
IT IS SO ORDERED.
Dated: October 14, 2026
DALE A. DROZD
UNITED STATES DISTRICT JUDGE
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