USA v. Arellanes-Jarquin

PARTIES’ JT. STMT.; [PROPOSED] ORDER
ARELLANES-JARQUIN, CR 26–70962 NC
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JODI LINKER
Federal Public Defender
Northern District of California
VARELL L. FULLER
Assistant Federal Public Defender
8th Floor - Suite 820
55 South Market Street
San Jose, CA 95113
Telephone: (408) 291-7753
Facsimile: (408) 291-7399
Email: Varell_Fuller@fd.org
Counsel for Defendant Arellanes-Jarquin
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA, Case No.: CR 26–70962 NC
PARTIES’ JOINT STATEMENT
REGARDING DISCOVERY AND
PROPOSED STIPULATIONS;
PROPOSED BRIEFING SCHEDULE
AND [PROPOSED] ORDER
Plaintiff,
v.
AARON ARELLANES-JARQUIN,
Defendant.
The parties in the above-captioned matter respectfully submit this joint statement
regarding the status of the case.
First, the parties have met and conferred regarding the defense’s discovery requests. The
government has advised that it will not produce any discovery in response to those requests.
See, e.g., Exb. B–C to Def.’s Mot. to Modify Dismissal Order, Dkt. No. 20.
Second, the parties continue to discuss whether they can reach stipulations on issues of
fact or law to streamline the evidentiary hearing. The defense maintains that the government’s
refusal to produce the requested discovery, including Mr. Arrelanes-Jarquin’s A-file, impedes
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PARTIES’ JT. STMT.; [PROPOSED] ORDER
ARELLANES-JARQUIN, CR 26–70962 NC
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defense counsel’s ability to meaningfully evaluate and agree to certain factual stipulations. The
government disagrees with this position.
Given the anticipated litigation over the outstanding discovery requests, the parties jointly
request that the Court vacate the October 29, 2026, evidentiary hearing and set a new date after
the Court resolves the outstanding discovery issues.
Accordingly, the parties respectfully propose the following schedule for the defense’s
motion to compel discovery:
Defense Motion: October 23, 2026
Government Opposition: November 6, 2026
Defense Reply: November 13, 2026
Hearing: To be set at the Court’s discretion.
In the event that the parties are able to reach stipulations, they will be submitted with the
defense motion.
Respectfully submitted,
DATED: October 9, 2026 CRAIG H. MISSAKIAN
United States Attorney
/s
NEAL HONG
Assistant United States Attorney
JODI LINKER
Federal Public Defender
DATED: October 9, 2026 /s
VARELL L. FULLER
Assistant Federal Public Defender
Counsel for Aaron Arellanes-Jarquin
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PARTIES’ JT. STMT.; [PROPOSED] ORDER
ARELLANES-JARQUIN, CR 26–70962 NC
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[PROPOSED] ORDER
GOOD CAUSE APPEARING, the Court hereby sets the following briefing schedule on
the defense’s motion to compel discovery:
Defense Motion: October 23, 2026
Government Opposition: November 6, 2026
Defense Reply: November 13, 2026
Hearing: To be set at the Court’s discretion.
The evidentiary hearing currently scheduled for October 29, 2026, is hereby VACATED.
IT IS SO ORDERED.
DATED: ___________________________________
NATHANAEL M. COUSINS
United States Magistrate Judge
October 9, 2026
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