Case 2:25-cr-00038-DJC Document 28 Filed 06/10/25 Page 1 of 3
1 MICHELE BECKWITH
Acting United States Attorney
2 SAM STEFANKI
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: (916) 554-2700
Facsimile: (916) 554-2900
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6 Attorneys for Plaintiff
United States of America
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8 IN THE UNITED STATES DISTRICT COURT
9 EASTERN DISTRICT OF CALIFORNIA
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11 UNITED STATES OF AMERICA, CASE NO. 2:25-CR-00038-DJC
12 Plaintiff, STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
13 v. FINDINGS AND ORDER
14 AKASH KUMAR SINGH, DATE: June 12, 2025
TIME: 9:00 a.m.
15 Defendant. COURT: Hon. Daniel J. Calabretta
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17 STIPULATION
18 Plaintiff United States of America (the “government”), by and through its counsel of record, and
19 defendant Akash Kumar Singh, by and through his counsel of record, hereby stipulate as follows:
20 1. By previous order, this matter was set for status on June 12, 2025.
21 2. By this stipulation, the defendant now moves to continue the status conference until
22 August 28, 2025, at 9:00 a.m., and to exclude time between June 12, 2025, and August 28, 2025, under
23 Local Code T4.
24 3. The parties agree and stipulate, and request that the Court find the following:
25 a) The government has represented that the discovery associated with this case
26 includes over 8,300 pages of documents and records, as well as video and audio recordings. All
27 of this discovery has been either produced directly to counsel and/or made available for
28 inspection and copying.
STIPULATION REGARDING EXCLUDABLE TIME 1
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00038-DJC Document 28 Filed 06/10/25 Page 2 of 3
1 b) Counsel for the defendant desires additional time to review the current charges,
2 conduct investigation and research related to the charges, review and copy produced discovery,
3 discuss potential resolutions with his client, and otherwise prepare for trial.
4 c) Counsel for the defendant believes that failure to grant the above-requested
5 continuance would deny him the reasonable time necessary for effective preparation, taking into
6 account the exercise of due diligence.
7 d) The government does not object to the continuance.
8 e) Based on the above-stated findings, the ends of justice served by continuing the
9 case as requested outweigh the interest of the public and the defendant in a trial within the
10 original date prescribed by the Speedy Trial Act.
11 f) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161,
12 et seq., within which trial must commence, the time period of June 12, 2025, to August 28, 2025,
13 inclusive, is deemed excludable pursuant to 18 U.S.C. § 3161(h)(7)(A), B(iv) [Local Code T4]
14 because it results from a continuance granted by the Court at the defendant’s request on the basis
15 of the Court’s finding that the ends of justice served by taking such action outweigh the best
16 interest of the public and the defendant in a speedy trial.
17 4. Nothing in this stipulation and order shall preclude a finding that other provisions of the
18 Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial
19 must commence.
20 IT IS SO STIPULATED.
21 Dated: June 9, 2025 MICHELE BECKWITH
Acting United States Attorney
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23 /s/ SAM STEFANKI
SAM STEFANKI
24 Assistant United States Attorney
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26 Dated: June 9, 2025 /s/ DOUGLAS BEEVERS
DOUGLAS BEEVERS
27 Counsel for Defendant
AKASH KUMAR SINGH
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STIPULATION REGARDING EXCLUDABLE TIME 2
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00038-DJC Document 28 Filed 06/10/25 Page 3 of 3
1 ORDER
2 IT IS SO FOUND AND ORDERED this 9th day of June, 2025.
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/s/ Daniel J. Calabretta
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THE HONORABLE DANIEL J. CALABRETTA
5 UNITED STATES DISTRICT JUDGE
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STIPULATION REGARDING EXCLUDABLE TIME 3
PERIODS UNDER SPEEDY TRIAL ACT