Stipulation Regarding Excludable Time Periods under Speedy Trial Act; Findings and Order — No. 2:25-cr-00191 (Dkt. 15, E.D. Cal.)

Summary

A three-page Stipulation Regarding Excludable Time Periods Under Speedy Trial Act, with findings and order, Document 15, filed 10/21/25 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 October 20, 2025 by Assistant United States Attorney Jessica Delaney and defense counsel Mark Reichel. The defendant moves to continue the status conference from October 23, 2025 to December 11, 2025 at 9:00 a.m. before Judge Daniel J. Calabretta: the government has produced more than 10,000 pages of discovery, including a complex tracing table, and defense counsel needs time to review it. The period October 23, 2025 to December 11, 2025 is excluded under 18 U.S.C. § 3161(h)(7)(A), B(iv), Local Code T4. Judge Calabretta so ordered on the 20th day of October, 2025.

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“Stipulation Regarding Excludable Time Periods under Speedy Trial Act; Findings and Order — No. 2:25-cr-00191 (Dkt. 15, E.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-regarding-excludable-time-periods-under-speedy-trial-act-f-425636a11b/, SHA-256 bb84e1591ed59b45aeb1c8c40209f37d56b6638dfedc898351ad55337e3de8de.

Full text

Case 2:25-cr-00191-DJC Document 15 Filed 10/21/25 Page 1 of 3

1 ERIC GRANT
United States Attorney
2 JESSICA DELANEY
Assistant United States Attorney
3 501 I Street, Suite 10-100
Sacramento, CA 95814
4 Telephone: (916) 554-2700
Facsimile: (916) 554-2900
5

6 Attorneys for Plaintiff
United States of America
7

8
IN THE UNITED STATES DISTRICT COURT
9
EASTERN DISTRICT OF CALIFORNIA
10

11 UNITED STATES OF AMERICA, CASE NO. 2:25-CR-0191 DJC
12 Plaintiff, STIPULATION REGARDING EXCLUDABLE
TIME PERIODS UNDER SPEEDY TRIAL ACT;
13 v. FINDINGS AND ORDER
14 OLEG GREGORVICH FURSOV, DATE: October 23, 2025
TIME: 9:00 a.m.
15 Defendant. COURT: Hon. Daniel J. Calabretta.
16

17 STIPULATION

18 1. By previous order, this matter was set for status on October 23, 2025.

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

20 December 11, 2025, at 9:00 a.m., and to exclude time between October 23, 2025, and December 11,

21 2025, under Local Code T4.

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

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

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

25 complex tracing table. All of this discovery has been produced directly to defense counsel. In

26 order to produce relevant PII, much of the discovery was produced pursuant to a protective

27 order.

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

STIPULATION REGARDING EXCLUDABLE TIME 1
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00191-DJC Document 15 Filed 10/21/25 Page 2 of 3

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

2 his client.

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

4 continuance would deny him the reasonable time necessary for effective preparation, taking into

5 account the exercise of due diligence.

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

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

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

9 original date prescribed by the Speedy Trial Act.

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

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

12 2025, inclusive, is deemed excludable pursuant to 18 U.S.C.§ 3161(h)(7)(A), B(iv) [Local Code

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

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

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

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

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

18 must commence.

19 IT IS SO STIPULATED.

20
Dated: October 20, 2025 ERIC GRANT
21 United States Attorney
22
/s/ JESSICA DELANEY
23 JESSICA DELANEY
Assistant United States Attorney
24

25
Dated: October 20, 2025 /s/ MARK REICHEL
26 MARK REICHEL
Counsel for Defendant
27 Oleg Gregorvich Fursov
28

STIPULATION REGARDING EXCLUDABLE TIME 2
PERIODS UNDER SPEEDY TRIAL ACT
Case 2:25-cr-00191-DJC Document 15 Filed 10/21/25 Page 3 of 3

3 ORDER

4 IT IS SO FOUND AND ORDERED this 20th day of October, 2025.

5
/s/ Daniel J. Calabretta
6
THE HONORABLE DANIEL J. CALABRETTA
7 UNITED STATES DISTRICT JUDGE

STIPULATION REGARDING EXCLUDABLE TIME 3
PERIODS UNDER SPEEDY TRIAL ACT

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