STIP. AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

United States v. Wilson et al., No CR 17-00028 JST

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Erik Babcock (Cal 172517)

LAW OFFICES OF ERIK BABCOCK

717 Washington St., 2d Floor

Oakland CA 94607

Telephone: (510) 452-8400

Facsimile: (510) 452-8405

erik@babcocklawoffice.com

Attorney for MARCUS WILSON

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

vs.

JEHOADDAN WILSON,

MARCUS WILSON,

Defendants.

No. CR 4:17-00028 JST

STIPULATION AND [PROPOSED]

ORDER TO CONTINUE STATUS 

CONFERENCE CURRENTLY SET 

FOR JANUARY 26, 2018 TO 

FEBRUARY 9, 2018

The parties, by and through their respective counsel, hereby agree as follows:

1. This case is set for a status conference on January 26, 2018. 

2. The parties agree and hereby stipulate that the January 26, 2018 status conference should 

be reset to February 9, 2018 at 9:30 a.m. for all defendants. This status conference date was originally 

set the assigned attorney for the government was AUSA Michelle Bazu. Ms. Bazu is no longer 

employed by the U.S. Attorney’s Office for the Northern District of California and the matter was just 

reassigned to AUSA Robert Rees. Additionally, counsel for both defendants have conflicting court 

appearances, including a trial calling in state court.

3. The defendants and the government all consent to the continuance of the status 
STIP. AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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conference, and the parties represent that good cause exists to exclude time under the Speedy Trial Act 

for this extension based on the defendants’ need for the effective preparation of counsel, taking into 

account the exercise of due diligence under 18 U.S.C. § 3161(h)(7)(B)(iv). For that reason, the parties 

request that the Court exclude from the time limits of 18 U.S.C. § 3161 the period from the date of this 

order through February 9, 2018 from the time period in which the defendants must be brought to trial. 

The parties also agree that the ends of justice served by granting such an exclusion of time outweigh the 

best interests of the public and the defendants in a speedy trial. See 18 U.S.C. § 3161(h)(7)(A).

IT IS SO STIPULATED.

Dated: January 23, 2018 ________/S/_____________________

ROBERT REES

Assistant United States Attorney

Dated: January 23, 2018 ________/S/_____________________

GEORGE BOISSEAU

Counsel for defendant 

JEHOADDAN WILSON

Dated: January 23, 2018 ________/S/_____________________

ERIK BABCOCK

Counsel for defendant 

MARCUS WILSON

[PROPOSED] ORDER GRANTING CONTINUANCE

The Court has reviewed the Stipulation of the parties to continue the January 26, 2018 status 

conference to February 9, 2018. Based on the stipulation of the parties, the Court finds good cause to 

continue the status conference to February 9, 2018 at 9:30 a.m. The Court further finds that exclusion of 

this period from the time limits applicable under 18 U.S.C. § 3161 is warranted; that the ends of justice 

served by the continuance outweigh the interests of the public and the defendant in the prompt 

disposition of this criminal case; and that the failure to grant the requested exclusion of time would deny 

counsel for the defendant and for the government the reasonable time necessary for effective preparation 

/ / /
STIP. AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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of counsel, taking into account the exercise of due diligence, and would result in a miscarriage of justice. 

18 U.S.C. § 3161(h)(7)(B)(iv).

IT IS SO ORDERED.

DATED: January 25, 2018 __________________________________

 Hon. Jon S. Tigar

United States District Court Judge