STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00028 JST

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BRIAN J. STRETCH (CABN 163973)

United States Attorney

BARBARA J. VALLIERE (DCBN 439353)

Chief, Criminal Division

MICHELLE BAZU (CABN 266964)

Assistant United States Attorney

1301 Clay Street, Suite 340S

Oakland, California 94612

Telephone: (510) 637-3680

FAX: (510) 637-3724

michelle.bazu@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 17-00028 JST

STIPULATION AND [PROPOSED] ORDER 

EXCLUDING TIME FROM DECEMBER 15, 

2017 TO JANUARY 26, 2018

IT IS HEREBY STIPULATED between the parties, Assistant United States Attorney, Michelle 

Bazu for Plaintiff United States of America, George Boisseau, counsel for defendant Jehoaddan Wilson, 

and Erik Babcock, counsel for defendant Marcus Wilson, that the status conference hearing presently 

scheduled for Friday, December 15, 2017 at 9:30 a.m., be continued to Friday, January 26, 2018 at 9:30 

a.m. 

The parties agree to exclude the time between December 15, 2017 and January 26, 2018 from the 

time in which the defendant must be brought to trial pursuant to the Speedy Trial Act, 18 U.S.C. § 3131 

et al. The government has engaged in discussion with defense counsel regarding a possible resolution of 
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00028 JST

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the pending case. Defense counsel continues to review the discovery, conduct further investigation and 

research, and will need additional time to discuss the discovery and the case with the defendants. 

Therefore, the parties agree that the time period of December 15, 2017 and January 26, 2018, inclusive, 

should be excluded pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (h)(7)(B)(iv) on the basis that the ends 

of justice served by the continuance outweigh the best interests of the public and defendant in a speedy 

trial, and failing to exclude this time would deny counsel the reasonable time necessary for effective 

preparation, taking into account the exercise of due diligence. 

DATED: December 12, 2017 /s/

GEORGE BOISSEAU

Counsel for Jehoaddan Wilson

DATED: December 12, 2017 /s/

ERIK BABCOCK

Counsel for Marcus Wilson

DATED: December 12, 2017 /s/

MICHELLE BAZU

Assistant United States Attorney
STIPULATION AND PROPOSED ORDER EXCLUDING TIME

CR 17-00028 JST

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ORDER

Based upon the representations of counsel and for good cause shown, the Court finds that failing 

to exclude the time between from December 15, 2017 through January 26, 2018 would deny counsel 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 December 15, 2017 through January 26, 2018 from computation under the Speedy Trial Act 

outweigh the best interests of the public and the defendant in a speedy trial. Therefore, IT IS HEREBY 

ORDERED that the time from December 15, 2017 through January 26, 2018 shall be excluded from 

computation under the Speedy Trial Act. 18 U.S.C. § 3161(h)(7)(A) and (B)(iv). 

DATED: 

HONORABLE JON S. TIGAR

United States District Judge

December 12, 2017

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

IT IS SO ORDERED

 Judge Jon S. Tigar