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 FEBRUARY 24, 2017 TO MARCH 

17, 2017 at 9:30 a.m.

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

1. This case is set for a status conference on February 24, 2017. 

2. The parties agree and hereby stipulate the February 24, 2017 status conference should be 

reset to March 17, 2017 at 9:30 a.m. for all defendants. This status conference date was originally set 

when Defendant Jehoaddan Wilson was arraigned. Counsel for Marcus Wilson was not appointed until 

a later date and is unavailable on February 24, 107. Additionally, the government has not yet provided 

defense counsel with any discovery in this case and will not do so until a Protective Order has been 

agreed upon and ordered by the court. The parties are still discussing the terms of a protective order and 

expect to submit one to the court soon. Once a protective order is signed by the court, it is expected that 

discovery will be provided to defense counsel soon. Both defendants are out of custody on bond. 

Case 4:17-cr-00028-JST Document 14 Filed 02/21/17 Page 1 of 3
STIP. AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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3. The defendants and the government all consent to the continuance of the status 

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 March 17, 2017 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: February 20, 2017 ________/S/_____________________

ROBERT REES

Assistant United States Attorney

Dated: February 20, 2017 ________/S/_____________________

ANGLEA HANSEN

Counsel for defendant 

JEHOADDAN WILSON

Dated: February 20, 2017 ________/S/_____________________

ERIK BABCOCK

Counsel for defendant 

MARCUS WILSON

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Case 4:17-cr-00028-JST Document 14 Filed 02/21/17 Page 2 of 3
STIP. AND [PROPOSED] ORDER TO CONTINUE STATUS CONFERENCE

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[PROPOSED] ORDER GRANTING CONTINUANCE

The Court has reviewed the Stipulation of the parties to continue the February 24, 2017 status

conference to March 17, 2017. Based on the stipulation of the parties, the Court finds good cause to 

continue the status conference to March 17, 2017 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 

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).

PURSUANT TO STIPULATION, IT IS SO ORDERED

DATED: February 21, 2017 __________________________________

 Hon. Jon S. Tigar

 United States District Court Judge

Case 4:17-cr-00028-JST Document 14 Filed 02/21/17 Page 3 of 3