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Case 2:25-cr-00179-DAD Document 31 Filed 12/05/25 Page 1 of 3
1 ERIC GRANT
United States Attorney
2 NCHEKUBE ONYIMA
Special 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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Attorneys for Plaintiff
6 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-00179-DAD
12 Plaintiff, STIPULATION TO CONTINUE STATUS
CONFERENCE AND EXCLUSION OF TIME
13 v. UNDER SPEEDY TRIAL ACT FINDINGS AND
ORDER
14 YOLANDA BUTLER, LEGERRIUS HOLT,
and QUAMAINE MASSEY, DATE: December 29, 2025
15 TIME: 9:30 a.m.
Defendants. COURT: Hon. Dale A. Drozd
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STIPULATION
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Plaintiff United States of America, by and through its attorney of record, Nchekube Onyima,
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Special Assistant United States Attorney, and defendants Yolanda Butler, Legerrius Holt, and Quamaine
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Massey both individually and by and through their counsels of record, Hootan Baigmohammadi, Kresta
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Daly, and Michael Hansen, hereby stipulate as follows:
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1. By previous order this matter was set for status on December 29, 2025, and excluded
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time from September 30, 2025, through December 29, 2025, under Local Code T4.
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2. By this stipulation, the defendants now move to continue the status conference until
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March 16, 2026, and to exclude time between December 29, 2025, and March 16, 2026, under Local
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Code T4.
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3. 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 thousands of pages of pages of documents,
STIPULATION TO CONTINUE AND EXCLUSION 1
30 OF TIME UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00179-DAD Document 31 Filed 12/05/25 Page 2 of 3
1 including police reports and images, financial records, and at least one forensic report of digital
2 devices. Some of this discovery is covered by a Protective Order.
3 b) Due to the nature of the discovery in this case, defendants’ counsels require
4 additional time to review the discovery, discuss potential resolution with their clients, and
5 otherwise prepare for trial.
6 c) Defendants’ counsels believe that failure to grant the above-requested
7 continuance would deny them the reasonable time necessary for effective preparation, taking into
8 account the exercise of due diligence.
9 d) The government does not object to the continuance.
10 e) Based on the above-stated findings, the ends of justice served by continuing the
11 case as requested outweigh the interest of the public and the defendants in a trial within the
12 original date prescribed by the Speedy Trial Act.
13 f) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161,
14 et seq., within which trial must commence, the time period of December 29, 2025 to March 16,
15 2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code
16 T4] because it results from a continuance granted by the Court at defendants’ request on the basis
17 of the Court’s finding that the ends of justice served by taking such action outweigh the best
18 interest of the public and the defendant in a speedy trial.
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STIPULATION TO CONTINUE AND EXCLUSION 2
30 OF TIME UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00179-DAD Document 31 Filed 12/05/25 Page 3 of 3
1 4. Nothing in this stipulation and order shall preclude a finding that other provisions of the
2 Speedy Trial Act dictate that additional time periods are excludible from the period within which a trial
3 must commence.
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5 IT IS SO STIPULATED.
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Dated: December 4, 2025 ERIC GRANT
7 United States Attorney
8 /s/ NCHEKUBE ONYIMA
NCHEKUBE ONYIMA
9 Special Assistant U.S. Attorney
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Dated: December 4, 2025 /s/HOOTAN BAIGMOHAMMADI
11 HOOTAN BAIGMOHAMMADI
Counsel for Defendant
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Yolanda Buter
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Dated: December 4, 2025 /s/KRESTA DALY
14 KRESTA DALY
Counsel for Defendant
15 Legerrius Holt
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Dated: December 4, 2025 /s/MICHAEL HANSEN
17 MICHAEL HANSEN
Counsel for Defendant
18 Quamaine Massey
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ORDER
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Pursuant to the stipulation of the parties and good cause appearing, the status conference in this
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case is continued from December 29, 2025, to March 16, 2026, at 9:30 a.m. and time is excluded
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through March 16, 2026 under Local Code T4.
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IT IS SO ORDERED.
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26 Dated: December 4, 2025
DALE A. DROZD
27 UNITED STATES DISTRICT JUDGE
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STIPULATION TO CONTINUE AND EXCLUSION 3
30 OF TIME UNDER SPEEDY TRIAL ACT