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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) 436-7200

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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CR 17-0028-JST

STIPULATION AND [PROPOSED] ORDER 

CONTINUING STATUS HEARING FROM 

JUNE 23, 2017 TO JULY 14, 2017 AND 

WAIVER OF 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. The parties are currently set for a status appearance on June 23, 2017 at 9:30AM before the 

Honorable Jon S. Tigar. Due to the unavailability of government counsel on that date, the parties hereby 

stipulate and agree to continue that status hearing three weeks to July 14, 2017 at 9:30AM.

2. The parties further stipulate and agree that an exclusion of time under the Speedy Trial Act from 

June 23, 2017 to July 14, 2017 is appropriate. The parties stipulate and agree that the ends of justice 
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served by that exclusion outweigh the best interest of the public and the defendant in a speedy trial 

because the case is complex within the meaning of 18 U.S.C. § 3161(h)(7)(A) and (B)(ii) due to the 

volume and complexity of income tax-related documents in the case and to preserve continuity of 

counsel as set forth in 18 U.S.C. § 3161(h)(7)(A) and (B)(iv).

IT IS SO STIPULATED

Dated: June 12, 2017 ___________/s_________________________

ROBERT DAVID REES

Assistant United States Attorney

Dated: June 12, 2017 ___________/s__________________________

ANGELA HANSEN, ESQ.

Assistant Federal Public Defender

Attorney for Defendant Jehoaddan Wilson

Dated: June 12, 2017 ___________/s_________________________

ERIK BABCOCK, ESQ.

Attorney for Defendant Marcus Wilson

[PROPOSED] ORDER

Upon stipulation by the parties and for good cause shown, IT IS HEREBY ORDERED THAT 

the status hearing currently scheduled for June 23, 2017 at 9:30AM is continued to July 14, 2017. The 

Court further finds and holds:

1. The defendants stipulate and agree to an exclusion of time under the Speedy Trial Act from 

June 23, 2017 to July 14, 2017. Failure to grant the requested continuance would unreasonably deny 

continuity of counsel as set forth in 18 U.S.C. § 3161(h)(7)(B)(iv). Furthermore, this case is complex 

within the meaning of § 3161(h)(7)(B)(ii).

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

time period set forth above outweigh the best interest of the public and the defendant in a speedy trial. '

3161(h)(7)(A).

3. Accordingly, and with the consent of the defendants, the Court orders that the time period set 

forth above be excluded from Speedy Trial Act calculations under 18 U.S.C. ' 3161(h)(8)(A), (B)(ii)
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and (B)(iv).

IT IS SO ORDERED.

Dated: June 13, 2017 ______________________________________

 THE HONORABLE JON S. TIGAR

 UNITED STATES DISTRICT JUDGE