STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME AND [PROPOSED] ORDER

CR 17-0083 MMC

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BRIAN J. STRETCH (CABN 163973)

United States Attorney

BARBARA J. VALLIERE (DCBN 439353)

Chief, Criminal Division

ANDREW F. DAWSON (CABN 264421)

Assistant United States Attorney

450 Golden Gate Avenue, Box 36055

San Francisco, California 94102-3495

Telephone: (415) 436-7019

FAX: (415) 436-7234

Andrew.Dawson@usdoj.gov

Attorneys for the United States

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

UNITED STATES OF AMERICA,

Plaintiff,

v.

RYAN RECAIDO PATACSIL, 

Defendant.

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CASE NO: CR 17-0083 MMC

STIPULATION TO CONTINUE STATUS 

CONFERENCE AND EXCLUDE TIME AND 

[PROPOSED] ORDER

The parties are currently set for a further status conference before this court on June 21, 2017. 

The parties are currently engaged in settlement discussions, and law enforcement review of the 

defendant’s many digital devices is ongoing. In light of this posture, the parties agree and stipulate to 

continue the upcoming status conference to August 2, 2017. The parties further submit this stipulation 

confirming their agreement that time should be excluded under the Speedy Trial Act pursuant to 18 

U.S.C. § 3161(h)(7)(A) and (B) between June 21, 2017 and August 2, 2017. Exclusion of time until 

August 2, 2017, will allow the defense to conduct further analysis of the evidence and is necessary for 

the effective preparation of counsel. See 18 U.S.C. § 3161(h)(7)(B)(iv).

IT IS SO STIPULATED.

DATED: June 15, 2017 /s/ ___

ANDREW F. DAWSON

Assistant United States Attorney
STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME AND [PROPOSED] ORDER

CR 17-0083 MMC

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DATED: June 15, 2017 /s/ ___

RYAN McHUGH

Attorney for Defendant Patacsil
STIPULATION TO CONTINUE STATUS CONFERENCE AND EXCLUDE TIME AND [PROPOSED] ORDER

CR 17-0083 MMC

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[PROPOSED] ORDER

Pursuant to the parties’ stipulation, the Court orders that the status conference currently set for 

June 21, 2017 be continued to August 2, 2017. The Court also finds that the exclusion of the period 

from June 21, 2017 to August 2, 2017 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 and of counsel, taking into account the exercise of due diligence, and 

would result in a miscarriage of justice. See 18 U.S.C. § 3161(h)(7)(B)(iv).

IT IS SO ORDERED. 

DATED: ___________________ ___________________________

HON. MAXINE M. CHESNEY

UNITED STATES DISTRICT JUDGE

June 16, 2017