SPEEDY TRIAL EXCLUSION

CR 17-0028 JST

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BRIAN J. STRETCH (CABN 163973)

United States Attorney

BARBARA J. VALLIERE (DCBN 439353)

Chief, Criminal Division

ROBERT DAVID REES (CABN 229441)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-7210

FAX: (415) 436-7234

Email: robert.rees@usdoj.gov

Attorneys for United States of America

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

OAKLAND DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

JEHOADDAN WILSON, and

MARCUS WILSON,

Defendants.

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Case No. CR 17-028 JST

STIPULATION AND [PROPOSED] ORDER

MEMORIALIZING EXCLUSIONS OF TIME 

UNDER THE SPEEDY TRIAL ACT

STIPULATION

The United States and defendants Jehoaddan Wilson and Marcus Wilson, through their 

respective undersigned counsel, hereby stipulate and agree as follows:

1. On March 17, 2017, the Court, with the agreement of the parties, ordered the exclusion of 

time under the Speedy Trial Act from March 17, 2017 to June 23, 2017 pursuant to 18 U.S.C. 

§ 3161(h)(7)(A) & (B)(ii). See Dkt. 18.

2. On July 14, 2017, the Court, with the agreement of the parties, ordered the exclusion of time 

under the Speedy Trial Act from July 14, 2017 to August 18, 2017 pursuant to 18 U.S.C. § 

3161(h)(7)(A) & (B)(ii). See Dkt. 23.
SPEEDY TRIAL EXCLUSION

CR 17-0028 JST

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3. On August 18, 2017, the Court, with the agreement of the parties, ordered the exclusion of

time under the Speedy Trial Act from August 18, 2017 to September 22, 2017 pursuant to 18 U.S.C.

§ 3161(h)(7)(A) & (B)(ii). See Dkt. 29.

4. On September 22, 2017, the Court, with the agreement of the parties, ordered the exclusion of 

time under the Speedy Trial Act from September 22, 2017 to November 3, 2017 pursuant to 18 U.S.C.

§ 3161(h)(7)(A) & (B)(ii). See Dkt. 32.

IT IS SO STIPULATED:

Dated: October 12, 2017 ___________/s_________________________

ROBERT DAVID REES

Assistant United States Attorney

Dated: October 4, 2017 ___________/s_________________________

GEORGE BOISSEAU, ESQ.

Attorney for Defendant Jehoaddan Wilson

Dated: October 4, 2017 ___________/s__________________________

ERIK BABCOCK, ESQ.

Attorney for Defendant Marcus Wilson
SPEEDY TRIAL EXCLUSION

CR 17-0028 JST

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[PROPOSED] ORDER

As to each time period set forth in the submission above and set forth below, the parties stipulate, 

and Court found and held as follows for each of the listed date ranges:

 March 17, 2017 to June 23, 2017;

 July 14, 2017 to August 18, 2017;

 August 18, 2017 to September 22, 2017; and

 September 22, 2017 to November 3, 2017; that

1. Failure to grant the requested continuance would unreasonably deny defense counsel 

reasonable time necessary for effective preparation, taking into account the exercise of due diligence. 

Furthermore, this case was found to be complex within the meaning of § 3161(h)(7)(B)(ii).

2. Given these circumstances, the Court found that the ends of justice served by excluding the 

time periods set forth above outweigh the best interest of the public and the defendants in a speedy trial. 

§ 3161(h)(8)(A).

3. Accordingly, and with the consent of the defendants, the Court ordered that the time periods 

set forth above be excluded from Speedy Trial Act calculations under 18 U.S.C. § 3161(h)(8)(A) & 

(B)(ii).

IT IS SO ORDERED.

Dated: October 12, 2017 _____________________________________

HON. JON S. TIGAR

United States District Court Judge