In Yandell’s view, the email proved the government was prosecuting him vindictively because he advocated for reforms within the California prison system, such as by leading a hunger strike against solitary confinement and gang validation policies.

One member of that group, Jeanna Quesenberry, was distributing large amounts of methamphetamine and heroin, and agents found evidence she was working in the community for Yandell, who was incarcerated in California state prison.

1 A snapshot of the page as it was available on January 26, 2024 is available on the internet archive via https://web.archive.org/web/20240126003206/https://nymag.com/news/ features/solitary-secure-housing-units-2014-2/ These threads came together in the summer of 2016, when Agent Nehring was exchanging recorded calls and text messages with Quesenberry under an assumed identity in an effort to collect evidence about her drug trafficking connections.

The government used the wiretaps to collect a great deal of evidence about the drug trafficking operation and the Aryan Brotherhood’s membership, leadership and efforts to exert influence within the California state prison system.

3 In Gomez-Lopez, the defense did offer the opinions of an expert sociologist, who opined that people with Latino surnames had been prosecuted at higher rates than others and concluded the difference could not be explained by random variation.

Defendant Brant Daniel, through counsel, and plaintiff United States, through counsel, hereby stipulate and request that the Court continue the deadline for defendant to file a reply brief to the government’s opposition to Mr. Daniel’s motion to vacate under 28 U.S.C. § 2255 from September 23, 2024 to October 7, 2024.

The reason for this request is that defense counsel needs additional time to consult with the defendant and prepare the reply brief.

Respectfully submitted,

IT IS HERBY ORDERED that the due date for defendant’s reply brief to the government’s opposition to defendant’s motion to vacate under 28 U.S.C. § 2255 is continued to October 7, 2024 Dated: October 1, 2024.

____________________________________) It is stipulated between the United States Attorney’s Office for the Eastern District of California by Assistant United States Attorney Alexis Klein, Esq. and Defendant Felicia Shaw through her attorney Philip Cozens, Esq., that: Defendant Shaw’s conditions of release are modified to appoint her mother, Rhonda Higgins, as her third-party custodian.

Pretrial Services has vetted Ms. Higgins, and she is an appropriate third-party custodian.

As such, the parties and Pretrial Services requests that the following condition be added: “You are released to the third-party custody of Rhonda Higgins, and you must reside with Ms. Higgins and not move or absent yourself from this residence for more than 24 hours without the prior approval of the pretrial services officer.” It is so stipulated.

The court, having read and considered the above-stipulation and finding good cause therefore, orders that Defendant Shaw’s conditions of release are modified to appoint her mother, Rhonda Higgins, as her third-party custodian.

As such, the parties and Pretrial Services requests that the following condition be added: “You are released to the third-party custody of Rhonda Higgins, and you must reside with Ms. Higgins and not move or absent yourself from this residence for more than 24 hours without the prior approval of the pretrial services officer.” Dated: September 19, 2024

The Government first produced discovery consisting of approximately 700 pages of Bates-stamped documents and over 73.9 gigabytes of native files, including cell phone databases and other items for defense review.

Since the start of the case, Defense counsel have been reviewing and analyzing the above, conducting legal research, meeting with their clients, and otherwise preparing for trial.

The above tasks are ongoing, and the defense requires additional time to review discovery, discuss the case with their clients and the Government, and continue to prepare.

The parties believe that failure to grant the requested continuance would deny defense counsel the reasonable time necessary for effective preparation, taking into account the exercise of due diligence.

Pursuant to the stipulation of the parties and good cause appearing, the status conference scheduled for September 24, 2024 is continued to December 17, 2024 at 9:30 a.m. and time is excluded under 18 U.S.C. § 3161(h)(7)(A), (B)(iv) (Local Code T4).

) ) ) ) ) ) ) ) ) ) ) Pursuant to the stipulation of the parties and for good cause shown, the conditions of release established by the Court on December 15, 2023, as set forth at docket entries 261, 263, and 264, and as modified on August 19, 2024, as set forth at docket entry 296, are temporarily modified as follows: 1) During the period September 16, 2024 through and including September 23, 2024, the curfew condition shall require Mr. Fraser to remain inside his residence from midnight until 6:00 a.m. 2) Beginning on September 24, 2024, the curfew shall revert back to the present period, which is 5:00 p.m. until 8:00 a.m. 3) All other conditions remain in full force and effect, including electronic monitoring.