United States v. Beltran

1

STIPULATION REGARDING EXCLUDABLE TIME

PERIODS UNDER SPEEDY TRIAL ACT

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

30

31

ERIC GRANT

United States Attorney

DAVID W. SPENCER

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.

ANTONIO BUENROSTRO SUAREZ, and

JESUS RAMON GONZALEZ,

Defendants.

CASE NO. 2:24-CR-0021-WBS

STIPULATION REGARDING EXCLUDABLE

TIME PERIODS UNDER SPEEDY TRIAL ACT;

FINDINGS AND ORDER

DATE: July 6, 2026 TIME: 10:00 a.m. COURT: Hon. William B. Shubb

STIPULATION

1. By previous order, this matter was set for status on July 6, 2026.

2. By this stipulation, defendants now move to continue the status conference until August 10, 2026, at 10:00 a.m., and to exclude time between July 6, 2026, and August 10, 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 more than 9,300 pages of reports, search warrants, and other materials, as well as numerous audio and video recordings, including wiretapped phone calls. All of this discovery has been either produced directly to counsel and/or made available for inspection.

b) On May 15, 2026, new counsel of record for defendant Antonio Buenrostro Suarez, Luis Bustamante, substituted into the case. See ECF 90.

1

c) Counsel for defendants desire additional time to consult with their clients, to review the current charges, to conduct investigation and research related to the charges, to review discovery in this matter, to discuss potential resolutions with their respective clients, and to otherwise prepare for trial.

d) Counsel for defendants believe 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 July 6, 2026 to August 10, 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. 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: July 1, 2026 ERIC GRANT United States Attorney /s/ DAVID W. SPENCER

DAVID W. SPENCER

Assistant United States Attorney

2