govinfo:USCOURTS-caed-2_25-cr-00269-7

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 STIPULATION REGARDING EXCLUDABLE TIME 
PERIODS UNDER SPEEDY TRIAL ACT 
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ERIC GRANT 
United States Attorney 
ADRIAN T. KINSELLA 
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. 
 
MARQUESE ALVIN ROBERTS, 
 
 Defendant. 
 
 
 

 
STIPULATION REGARDING EXCLUDABLE 
TIME PERIODS UNDER SPEEDY TRIAL ACT; 
[PROPOSED] FINDINGS AND ORDER 
 
DATE: June 10, 2026 
TIME: 9:30 a.m. 
COURT: Hon. Dena Coggins 
 
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 June 10, 2026. ECF No. 29. Time 
has been excluded until this date. Id. The related case is set for an Admit/Deny hearing on the same 
date. 2:18-CR-00018-DC, ECF No. 93. 
2. By this stipulation, defendant now moves to reset the status conference for August 7, 
2026, and to exclude time between June 10, 2026, and August 7, 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 CHP helicopter footage, body camera footage, reports, a forensic cellular phone 
extraction, and other evidence. All of this discovery is in the process of been either produced 

 
 
 
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 STIPULATION REGARDING EXCLUDABLE TIME 
PERIODS UNDER SPEEDY TRIAL ACT 
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directly to counsel and/or made available for inspection and copying. Much of this discovery is 
subject to a protective order. 
b) Counsel for defendant desires additional time consult with his client, to review the 
current charge, to conduct investigation and research related to the charge, to review and copy 
discovery for this matter, to discuss potential resolutions with his client, to prepare pretrial 
motions, and to otherwise prepare for trial. Additionally, Counsel for defendant recently 
substituted in as new counsel of record. 
c) Counsel for defendant believes that failure to grant the above-requested 
continuance would deny him/her 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 June 10, 2026 to August 7, 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. 
 
// 
 
// 
 
// 
 
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 STIPULATION REGARDING EXCLUDABLE TIME 
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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: June 8, 2026 ERIC GRANT 
United States Attorney 
 
 
/s/ ADRIAN T. KINSELLA 
 ADRIAN T. KINSELLA 
Assistant United States Attorney 
 
 
Dated: June 8, 2026 /s/ TAMARA SOLOMON 
 TAMARA SOLOMON 
Counsel for Defendant 
MARQUESE ALVIN ROBERTS 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 

 
 
 
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 STIPULATION REGARDING EXCLUDABLE TIME 
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ORDER 
IT IS HEREBY ORDERED, the court, having received, read and considered the parties’ 
stipulation filed on June 8, 2026 (Doc. No. 31), and good cause appearing therefrom, APPROVES the 
parties’ stipulation. Accordingly, the Status Conference scheduled for June 10, 2026, is VACATED and 
RESET for August 7, 2026 at 9:30 a.m. in Courtroom 10 before the Honorable Dena M. Coggins. The 
time period between June 10, 2026 and August 7, 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 defendants in a speedy trial. 
 
IT IS SO ORDERED. 
 
Dated: June 8, 2026 
 
 
 
___________________________ 
Dena Coggins 
United States District Judge 

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