Stipulation to Continue Hearing and for Exclusion of Time pursuant to the Speedy Trial Act and F.r.c.p — No. 3:20-mj-70483 (Dkt. 18, N.D. Cal.)

Summary

A three-page Stipulation to Continue Hearing and for Exclusion of Time Pursuant to the Speedy Trial Act and F.R.C.P. 5.1(d), Document 18, filed 09/01/20 in United States v. Rodney L. Stevenson II, Case No. 3:20-MJ-70483, in the U.S. District Court for the Northern District of California, San Francisco Division, signed September 1, 2020 by Assistant United States Attorney Colin Sampson and by Ryan D'Ambrosio and Jeremy Ross for the defendant. The complaint was unsealed after Stevenson's arrest on April 28, 2020; the government has since produced approximately 10,000 pages of discovery. The order, dated September 1, 2020, continues the status conference and preliminary hearing from September 3, 2020 to October 21, 2020 at 11:00 a.m., excludes time under the Speedy Trial Act and Rule 5.1(d), and lets the defendant appear by video.

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“Stipulation to Continue Hearing and for Exclusion of Time pursuant to the Speedy Trial Act and F.r.c.p — No. 3:20-mj-70483 (Dkt. 18, N.D. Cal.).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/stipulation-to-continue-hearing-and-for-exclusion-of-time-pursuant-to-d68d0a8178/, SHA-256 7c8641da48037cdba827fd0327c8d254b9301a367d15836464b8a8288fb24316.

Full text

Case 3:20-mj-70483-AGT Document 18 Filed 09/01/20 Page 1 of 3

1 DAVID L. ANDERSON (CABN 149604)
United States Attorney
2
HALLIE HOFFMAN (CABN 210020)
3 Chief, Criminal Division

4 COLIN C. SAMPSON (CABN 249784)
450 Golden Gate Avenue, Box 36055
5 San Francisco, California 94102-3495
Telephone: (415) 436-7200
6 FAX: (415) 436-7234
Colin.Sampson@usdoj.gov
7
Attorneys for United States of America
8
RYAN D’AMBROSIO (CABN 299011)
9 JEREMY ROSS (CABN 294582)
D'Ambrosio | Ross LLP
10 1055 W. 7th St. 33rd Fl.
Los Angeles, CA 90017
11 Telephone: (213) 459-6385
Ryan@dambrosioross.com
12 Jeremy@dambrosioross.com

13 Attorneys for Rodney L. Stevenson II

14 UNITED STATES DISTRICT COURT

15 NORTHERN DISTRICT OF CALIFORNIA

16 SAN FRANCISCO DIVISION

17 UNITED STATES OF AMERICA, ) CASE NO. 3:20-MJ-70483
)
18 Plaintiff, ) STIPULATION TO CONTINUE
) HEARING AND FOR EXCLUSION
19 v. ) OF TIME PURSUANT TO THE
) SPEEDY TRIAL ACT AND F.R.C.P.
20 RODNEY L. STEVENSON II, ) 5.1(d)
)
21 Defendant. )
)
22

23 The United States of America, represented by Colin Sampson, and defendant Rodney L.

24 Stevenson II, represented by Ryan D’Ambrosio and Jeremy Ross, hereby STIPULATE and AGREE as

25 follows:

26 The Complaint against defendant was filed in the Northern District of California on April 24,

27 2020, and unsealed after defendant’s arrest on April 28, 2020. ECF Nos. 1, 3. Defendant was arraigned

28 in the Western District of Michigan on April 28, 2020, and was ordered to appear before the United

1
Case 3:20-mj-70483-AGT Document 18 Filed 09/01/20 Page 2 of 3

1 States District Court for the Northern District of California on July 16, 2020. Defendant has waived

2 time between April 28, 2020 and September 3, 2020, pursuant to Federal Rule of Criminal Procedure

3 5.1(d) and 18 U.S.C. §§ 3161(b), (h)(7)(A) and (h)(7)(B)(iv). Since July 9, 2020, pursuant to a

4 protective order (ECF No. 9), the United States has produced approximately 10,000 pages of discovery.

5 The parties have recently met and conferred regarding discovery. Given the need to review

6 discovery and adequately prepare for any preliminary hearing or other proceeding, the parties jointly

7 request and move the Court to continue the Preliminary Hearing from Thursday, September 3, 2020, to

8 Wednesday, October 21, 2020.

9 Respectfully submitted,

10 DAVID L. ANDERSON
United States Attorney
11

12 Dated: September 1, 2020. /s/ Colin Sampson
COLIN SAMPSON
13 Assistant United States Attorneys

14 Attorneys for the United States of America

15 Dated: September 1, 2020. /s/ Ryan D’Ambrosio
RYAN D’AMBROSIO
16 JEREMY ROSS
D’Ambrosio Ross LLP
17
Attorneys for Defendant Rodney L. Stevenson II
18
19

2
Case 3:20-mj-70483-AGT Document 18 Filed 09/01/20 Page 3 of 3

3
UNITED STATES DISTRICT COURT
4
NORTHERN DISTRICT OF CALIFORNIA
5
SAN FRANCISCO DIVISION
6

7
UNITED STATES OF AMERICA, ) CASE NO. 3:20-MJ-70483
8 )
Plaintiff, ) [PROPOSED] ORDER EXCLUDING
9 ) TIME PURSUANT TO THE SPEEDY
v. ) TRIAL ACT AND F.R.C.P. 5.1(d)
10 )
RODNEY L. STEVENSON II, )
11 )
Defendant. )
12 )

13 Pursuant to the consent and stipulation of defendant Rodney L. Stevenson, II and his counsel,

14 and The United States of America and its counsel, and for good cause shown,

15 IT IS ORDERED THAT the status conference and preliminary hearing scheduled for September

16 3, 2020, is continued to October 21, 2020, at 11:00 a.m. It is further

17 ORDERED THAT time under the Speedy Trial Act and Federal Rule of Criminal Procedure 5.1

18 as to Rodney L. Stevenson II is excluded from the date of this Order until October 21, 2020, pursuant to
19 18 U.S.C. §§ 3161(b), (h)(7)(A) and (B)(iv) and Federal Rule of Criminal Procedure 5.1(d), at the

20 consent of the defendant and for continuity of defense counsel and effective preparation, taking into

21 account the exercise of due diligence. It is further

22 ORDERED THAT defendant has consented to and may appear at the hearing currently

23 scheduled for October 21, 2020, by video teleconference.

24
IT IS SO ORDERED.
25

26 Dated: September 1, 2020
_________________ __________________________________________
THE HONORABLE NATHANAEL M. COUSINS
27 UNITED STATES MAGISTRATE JUDGE
28 VIRGINIA K. DEMARCHI

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