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Joint Stipulation and Order to Continue Status Conference — United States v. Loloee (E.D. Cal., Dkt. 158)

Summary

Joint stipulation and order to continue a status conference, filed September 4, 2025 as Document 158 in United States v. Shahriar "Sean" Loloee et al., Case No. 2:23-CR-00320-TLN, in the U.S. District Court for the Eastern District of California. The parties ask to vacate the status conference set for September 18, 2025, at 9:30 AM and continue it to October 9, 2025, citing a medical procedure of Mr. Loloee. They also ask to exclude time under the Speedy Trial Act from September 23, 2025, to October 9, 2025, under Local Code T4, and the government does not object. Chief Judge Troy L. Nunley's order reads "IT IS SO ORDERED," dated September 3, 2025.

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“Joint Stipulation and Order to Continue Status Conference — United States v. Loloee (E.D. Cal., Dkt. 158).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-e-d-cal-no-2-23-cr-00320-dkt-158-e-d-cal-e4890cb63e/, SHA-256 3d7af80a78a18105c69d8b83a5d578f002c6821537209a9ca4ceb931b86b9091.

Full text

                                 Case 2:23-cr-00320-TLN       Document 158       Filed 09/04/25     Page 1 of 4


                             1   BUCHALTER
                                 A Professional Corporation
                             2   SHERRY HAUS (SBN: 215123)
                                 500 Capitol Mall, Suite 1900
                             3   Sacramento, CA 95814
                                 Telephone: 916.945.5170
                             4   Email: shaus@buchalter.com

                             5   LAW OFFICE OF KEVIN J. ROONEY, P.C.
                                 KEVIN ROONEY (SBN 282017)
                             6   3425 Brookside Road, Suite A
                                 Stockton, CA 95219
                             7   T: (209) 200-8729
                                 Email: kevin@kevinrooneylaw.com
                             8
                                 LAW OFFICE OF THOMAS A. JOHNSON
                             9   THOMAS A. JOHNSON (SBN 119203)
                                 400 Capitol Mall, Suite 2560
                       10        Sacramento, CA 95814
                                 T: (916) 442-4022
                       11        Email: taj@tomjohnsonlaw.com

                       12        Attorneys for Defendant
                                 SEAN LOLOEE
                       13
                       14                                   UNITED STATES DISTRICT COURT

                       15                                  EASTERN DISTRICT OF CALIFORNIA

                       16                                      SACRAMENTO DIVISION

                       17 UNITED STATES OF AMERICA,                               Case No. 2:23-CR-00320-TLN

                       18                    Plaintiff,                           JOINT STIPULATION AND ORDER TO
                                                                                  CONTINUE STATUS CONFERENCE
                       19             vs.
                                                                                  Date:       September 18, 2025
                       20        SHAHRIAR “SEAN” LOLOEE, KARLA                    Time:       9:30 AM
                                 MONTOYA, MIRWAIS SHAMS, and AHMAD                Judge:      Hon. Troy L. Nunley
                       21        “SHAH” SHAMS,

                       22                    Defendants.

                       23                                          STIPULATION
                       24             1.     Defendants Sean Loloee, Karla Montoya, Mirwais Shams, and Shah Shams, by

                       25 and through their undersigned counsel, and the United States, through its undersigned counsel,
                       26 hereby agree and request that the status conference currently set for Thursday, September 18,
                       27 2025, at 9:30 AM, be vacated and continued until Thursday, October 9, 2025, at 9:30 AM.
                       28             2.     The parties agree that a short continuance is necessary due to a medical procedure
     BUCHALTER
A PROFESSIONAL CORPORATION
       SACRAMENTO
                                 Case 2:23-cr-00320-TLN            Document 158         Filed 09/04/25      Page 2 of 4


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                                 of Mr. Loloee.
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                                        3.        By previous order, this matter was set for status on July 10, 2025. (Mins., ECF No.
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                                 155.) Also by previous order, time under the Speedy Trial Act was excluded through September
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                                 23, 2025. (Order, ECF No. 153.)
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                                        4.        By this stipulation, the parties now request that the Court enter an order excluding
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                                 time under the Speedy Trial Act between September 23, 2025, and October 9, 2025, under Local
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                                 Code T4.
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                                        5.        The parties agree and stipulate, and request that the Court find the following:
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                                                  a)      The discovery in this case consists of at least ten terabytes of data that was
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                                        previously produced to defense counsel on multiple hard drives. The discovery in this case
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                                        also includes dozens of boxes of physical employment records, which must be reviewed in
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                                        person, which has been either produced directly to defense counsel and/or made available
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                                        for inspection and copying. To date, defense counsel has reviewed hundreds of thousands
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                                        of pages of discovery and the government continues to produce discovery.
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                                                  b)      The government does not object to the requested exclusion of time.
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                                                  c)      Based on the above-stated findings, the ends of justice served by excluding
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                                        time as requested outweigh the interest of the public and the defendants in a trial within
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                                        the original date prescribed by the Speedy Trial Act.
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                                                  d)      For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. §
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                                        3161, et seq., within which trial must commence, the time period of September 23, 2025,
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                                        to October 9, 2025, inclusive, is deemed excludable pursuant to 18 U.S.C. §
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                                        3161(h)(7)(A), B(iv) [Local Code T4] because it results from an exclusion granted by the
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                                        Court at the defendants’ request on the basis of the Court’s finding that the ends of justice
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                                        served by taking such action outweigh the best interest of the public and the defendants in
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                                        a speedy trial.
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                                        6.        Nothing in this stipulation and order shall preclude a finding that other provisions
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                                 of the Speedy Trial Act dictate that additional time periods are excludable from the period within
                       28
     BUCHALTER
A PROFESSIONAL CORPORATION
       SACRAMENTO
                                 Case 2:23-cr-00320-TLN         Document 158   Filed 09/04/25     Page 3 of 4


                             1
                                 which a trial must commence.
                             2
                                         IT IS SO STIPULATED.
                             3
                                  Dated: September 3, 2025                     ERIC GRANT
                             4                                                 Interim United States Attorney
                             5
                                                                               /s/ SAM STEFANKI
                             6    fair                                         AUDREY HEMESATH
                                                                               MATTHEW THUESEN
                             7                                                 SAM STEFANKI
                                                                               Assistant United States Attorneys
                             8
                             9    Dated: September 3, 2025                     /s/ SHERRY D.H. HAUS
                                                                               SHERRY D.H. HAUS
                       10                                                      Counsel for Defendant SEAN LOLOEE
                       11         Dated: September 3, 2025                     /s/ KEVIN JAMES ROONEY
                                                                               KEVIN JAMES ROONEY
                       12
                                                                               Counsel for Defendant SEAN LOLOEE
                       13         Dated: September 3, 2025                     /s/ THOMAS A. JOHNSON
                                                                               THOMAS A. JOHNSON
                       14                                                      Counsel for Defendant SEAN LOLOEE
                       15         Dated: September 3, 2025                     /s/ WILIAM J. PORTANOVA
                       16                                                      WILLIAM J. PORTANOVA
                                                                               Counsel for Defendant KARLA MONTOYA
                       17
                                  Dated: September 3, 2025                     /s/ MICHAEL D. LONG
                       18                                                      MICHAEL D. LONG
                                                                               Counsel for Defendant MIRWAIS SHAMS
                       19
                       20         Dated: September 3, 2025                     /s/ TIMOTHY E. WARRINER
                                                                               TIMOTHY E. WARRINER
                       21                                                      Counsel for Defendant AHMAD SHAMS
                       22
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     BUCHALTER
A PROFESSIONAL CORPORATION
       SACRAMENTO
                                 Case 2:23-cr-00320-TLN     Document 158    Filed 09/04/25   Page 4 of 4


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                             2
                                                                           ORDER
                             3
                                       IT IS SO ORDERED.
                             4
                                 Dated: September 3, 2025
                             5                                                 ____________________________
                                                                               Troy L. Nunley
                             6                                                 Chief United States District Judge
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     BUCHALTER
A PROFESSIONAL CORPORATION
       SACRAMENTO


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