Stipulation Regarding Excludable Time Periods under Speedy Trial Act; Findings and Order — No. 2:25-cr-00191 (Dkt. 17, E.D. Cal.)

Summary

A three-page Stipulation Regarding Excludable Time Periods Under Speedy Trial Act, with findings and order, Document 17, filed 12/03/25 in United States v. Oleg Gregorvich Fursov, Case No. 2:25-CR-0191 DJC, in the U.S. District Court for the Eastern District of California, signed December 2, 2025 by Assistant United States Attorney Jessica Delaney and defense counsel Mark Reichel. The defendant moves to continue the status conference from December 11, 2025 to February 5, 2026 at 9:00 a.m. before Judge Daniel J. Calabretta: the government has produced more than 10,000 pages of discovery, and defense counsel needs time to review it and is unavailable on the 11th. The period December 11, 2025 to February 5, 2026 is excluded under 18 U.S.C. § 3161(h)(7)(A), B(iv), Local Code T4. Judge Calabretta so ordered on the 2nd day of December, 2025.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Cite this document

“Stipulation Regarding Excludable Time Periods under Speedy Trial Act; Findings and Order — No. 2:25-cr-00191 (Dkt. 17, E.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-regarding-excludable-time-periods-under-speedy-trial-act-f-1ca6f32829/, SHA-256 62475c9c8c0d066a9b547b4a2bf300e2e4364f420708c65a5b1a6dff7f873d69.

Full text

Case 2:25-cr-00191-DJC Document 17 Filed 12/03/25 Page 1 of 3

1 REICHELLAW PC
MARK REICHEL
2 Attorney at Law
SBN: 155034
3 455 Capitol Mall, Suite 802
Sacramento, CA 95814
4 Telephone: (916) 548-7398
Facsimile: (888) 505-9331
5 mark@reichellaw.com
www.reichellaw.com
6

7 Attorney for Defendant
Oleg Gregorvich Fursov
8

9
IN THE UNITED STATES DISTRICT COURT
10
EASTERN DISTRICT OF CALIFORNIA
11

12 UNITED STATES OF AMERICA, CASE NO. 2:25-CR-0191 DJC
13 Plaintiff, STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
14 v. FINDINGS AND ORDER
15 OLEG GREGORVICH FURSOV, DATE: February 5, 2026
TIME: 9:00 a.m.
16 Defendant. COURT: Hon. Daniel J. Calabretta.
17

STIPULATION REGARDING EXCLUDABLE TIME 1
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00191-DJC Document 17 Filed 12/03/25 Page 2 of 3

1 STIPULATION

2 1. By previous order, this matter was set for status on December 11, 2025.

3 2. By this stipulation, defendant now moves to continue the status conference until February

4 5, 2026, at 9:00 a.m., and to exclude time between December 11, 2025, and February 5, 2026, under

5 Local Code T4.

6 3. The parties agree and stipulate, and request that the Court find the following:

7 a) The government has produced more than 10,000 pages of discovery consisting of

8 financial documentation, audio recordings, and investigative reports. Included the discovery is a

9 complex tracing table. All discovery has been produced directly to defense counsel. To produce

10 relevant PII, much of the discovery was produced pursuant to a protective order.

11 b) Counsel for defendant Oleg Fursov desires additional time to review discovery,

12 research the charge and potential defenses, conduct independent investigation, and consult with

13 his client. Further, defense counsel is unavailable on the 11th; they are representing a grand jury

14 witness on a public corruption case and that date cannot be changed.

15 c) Counsel for the defendant believes that failure to grant the above-requested

16 continuance would deny him the reasonable time necessary for effective preparation, considering

17 the exercise of due diligence.

18 d) The government does not object to the continuance.

19 e) Based on the above-stated findings, the ends of justice served by continuing the

20 case as requested outweigh the interest of the public and the defendant in a trial within the

21 original date prescribed by the Speedy Trial Act.

22 f) For the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161,

23 et seq., within which trial must commence, the time period of December 11, 2025 to February 5,

24 2026, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code

25 T4] because it results from a continuance granted by the Court at defendant’s request on the basis

26 of the Court’s finding that the ends of justice served by taking such action outweigh the best

27 interest of the public and the defendant in a speedy trial.

28 4. Nothing in this stipulation and order shall preclude a finding that other provisions of the

STIPULATION REGARDING EXCLUDABLE TIME 2
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00191-DJC Document 17 Filed 12/03/25 Page 3 of 3

1 Speedy Trial Act dictate that additional time periods are excludable from the period within which a trial

2 must commence.

3 IT IS SO STIPULATED.

4
Dated: December 2, 2025 ERIC GRANT
5 United States Attorney
6
/s/ JESSICA DELANEY
7 JESSICA DELANEY
Assistant United States Attorney
8

9
Dated: December 2, 2025 /s/ MARK REICHEL
10 MARK REICHEL
Counsel for Defendant
11 Oleg Gregorvich Fursov
12

15
ORDER
16
IT IS SO FOUND AND ORDERED this 2nd day of December, 2025.
17

18 /s/ Daniel J. Calabretta
19 THE HONORABLE DANIEL J. CALABRETTA
UNITED STATES DISTRICT JUDGE
20

STIPULATION REGARDING EXCLUDABLE TIME 3
PERIODS UNDER SPEEDY TRIAL ACT

File and source

File: 17.pdf
Size: 122,023 bytes
SHA-256: 62475c9c8c0d066a9b547b4a2bf300e2e4364f420708c65a5b1a6dff7f873d69
Our copy: 17.pdf
Original: No public link identified.