govinfo:USCOURTS-cand-3_26-cr-00090-1

STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER v. 9/18/2025 
Case No. 26-cr-00090 CRB 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 
 
 
CRAIG H. MISSAKIAN (CABN 125202) 
United States Attorney 
 
JEFF MITCHELL (CABN 236225) 
Chief, Criminal Division 
 
ASEEM PADUKONE (CABN 298812) 
Assistant United States Attorney 
 
450 Golden Gate Avenue, Box 36055 
San Francisco, California 94102-3495 
Telephone: (415) 436-6401 
FAX: (415) 436-7234 
Aseem.padukone@usdoj.gov 
 
Attorneys for United States of America 
 
UNITED STATES DISTRICT COURT 
 
NORTHERN DISTRICT OF CALIFORNIA 
 
SAN FRANCISCO DIVISION 
 
UNITED STATES OF AMERICA, 
Plaintiff, 
v. 
JENNIFER VACA, 
Defendant. 
) 
) 
) 
) 
) 
) 
) 
) 
) 
) 
NO. 26-cr-00090 CRB 
 
JOINT MOTION TO CONTINUE; STIPULATION 
TO EXCLUDE TIME FROM JUNE 24, 2026, TO 
AUGUST 18, 2026, AND [P ROPOSED] ORDER 
 
 
 
 
It is hereby stipulated by and between counsel for the United States and counsel for the 
defendant JENNIFER VACA, that time be excluded under the Speedy Trial Act from June 24, 2026, 
through August 18, 2026. 
At the status conference held on May 7, 2026, the parties requested that a hearing be set for June 
24, 2026, since the defense was still reviewing discovery and the parties had hoped that they may be 
able to reach a resolution by that date. The Court excluded time under the Speedy Trial Act through 
June 24, 2026. The government now expects to obtain an indictment in this case, and the parties do not 
expect to reach a resolution. Accordingly, the parties wish to continue the June 24, 2026 hearing to 
August 18, 2026, for a trial-setting hearing. The government estimates that trial in this case would last 
no longer than one week. Given the posture of this case and the need to prepare for trial, the parties 

 
 
 
STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER v. 9/18/2025 
Case No. 26-cr-00090 CRB 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 
 
 
again request that the Court exclude time under the Speedy Trial Act so that defense counsel could 
continue to prepare, including by reviewing the discovery already produced. 
For this reason, the parties stipulate and agree that excluding time until August 18, 2026, will 
allow for the effective preparation of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv). The parties further 
stipulate and agree that the ends of justice served by excluding the time from June 24, 2026, through 
August 18, 2026, from computation under the Speedy Trial Act outweigh the best interests of the public 
and the defendant in a speedy trial. 18 U.S.C. § 3161(h)(7)(A), (B)(iv). 
The undersigned Assistant United States Attorney certifies that he has obtained approval from 
counsel for the defendant to file this stipulation and proposed order. 
 
IT IS SO STIPULATED. 
DATED: June 15, 2026 /s/ 
 ASEEM PADUKONE 
Assistant United States Attorney 
 
 
DATED: June 15, 2026 /s/ 
 ERICK GUZMAN 
 Counsel for Defendant JENNIFER VACA 
 

 
 
 
STIPULATION TO EXCLUDE TIME AND [PROPOSED] ORDER v. 9/18/2025 
Case No. 26-cr-00090 CRB 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 
 
 
[PROPOSED] ORDER 
Based upon the facts set forth in the stipulation of the parties, and for good cause shown, the 
Court finds that failing to exclude the time from June 24, 2026, through August 18, 2026, would 
unreasonably deny defense counsel and the defendant the reasonable time necessary for effective 
preparation, taking into account the exercise of due diligence. 18 U.S.C. § 3161(h)(7)(B)(iv). The Court 
further finds that the ends of justice served by excluding the time from June 24, 2026, to August 18, 
2026, from computation under the Speedy Trial Act outweigh the best interests of the public and the 
defendant in a speedy trial. Therefore, and with the consent of the parties, IT IS HEREBY ORDERED 
that the status conference set for June 24, 2026 is continued to August 18, 2026, and that the time from 
June 24, 2026, through August 18, 2026, shall be excluded from computation under the Speedy Trial 
Act. 18 U.S.C. § 3161(h)(7)(A), (B)(iv). 
IT IS SO ORDERED. 
 
DATED: ___________________ ___________________________ 
 CHARLES R. BREYER 
 Senior United States District Judge 
June 16, 2026

Passage view · GavelSight