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Case 2:25-cr-00179-DAD Document 33 Filed 03/11/26 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: March 16, 2026
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 previous order this matter was set for status on March 16, 2026, and excluded time
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from December 29, 2025, through March 16, 2026, under Local Code T4.
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3. By this stipulation, the defendants now move to continue the status conference until July
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27, 2026, and to exclude time between March 16, 2026, and July 27, 2026, under Local Code T4.
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4. The parties agree and stipulate, and request that the Court find the following:
STIPULATION TO CONTINUE AND EXCLUSION 1
30 OF TIME UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00179-DAD Document 33 Filed 03/11/26 Page 2 of 3
1 a) The discovery in this case consists of over 60,000 pages of documents, including
2 financial records, police reports, images, and forensic reports of digital devices. The majority of
3 this discovery is covered by a Protective Order.
4 b) The parties are also working on setting a date to meet with the government and its
5 case agents in this case to discuss the discovery and possible resolution.
6 c) Due to the nature of the discovery in this case, and the upcoming meeting with the
7 government’s case agents, defendants’ counsels require additional time to review the discovery,
8 discuss potential resolution with their clients, and otherwise prepare for trial.
9 d) Defendants’ counsels believe that failure to grant the above-requested
10 continuance would deny them the reasonable time necessary for effective preparation, taking into
11 account the exercise of due diligence.
12 e) The government does not object to the continuance.
13 f) Based on the above-stated findings, the ends of justice served by continuing the
14 case as requested outweigh the interest of the public and the defendants in a trial within the
15 original date prescribed by the Speedy Trial Act.
16 g) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161,
17 et seq., within which trial must commence, the time period of March 16, 2026 to July 27, 2026,
18 inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code T4]
19 because it results from a continuance granted by the Court at defendants’ request on the basis of
20 the Court’s finding that the ends of justice served by taking such action outweigh the best interest
21 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 33 Filed 03/11/26 Page 3 of 3
1 5. 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.
4 IT IS SO STIPULATED.
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Dated: March 11, 2026 ERIC GRANT
6 United States Attorney
7 /s/ NCHEKUBE ONYIMA
NCHEKUBE ONYIMA
8 Special Assistant U.S. Attorney
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Dated: March 11, 2026 /s/HOOTAN BAIGMOHAMMADI
10 HOOTAN BAIGMOHAMMADI
Counsel for Defendant
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Yolanda Buter
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Dated: March 11, 2026 /s/KRESTA DALY
13 KRESTA DALY
Counsel for Defendant
14 Legerrius Holt
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Dated: March 11, 2026 /s/MICHAEL HANSEN
16 MICHAEL HANSEN
Counsel for Defendant
17 Quamaine Massey
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ORDE R
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20 Pursuant to the stipulation of the parties and good cause appearing, the status conference
21 previously scheduled for March 16, 2026 is continued to July 27, 2026, at 9:30 a.m. and time is
22 excluded between March 16, 2026, and July 27, 2026, under Local Code T4. However, no further
23 continuances of the of the status conference in this case will be granted absent a compelling
24 showing of good cause.
25 IT IS SO ORDERED.
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Dated: March 11, 2026
27 DALE A. DROZD
UNITED STATES DISTRICT JUDGE
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STIPULATION TO CONTINUE AND EXCLUSION 3
30 OF TIME UNDER SPEEDY TRIAL ACT