Case 5:18-cr-00258-EJD Document 80 Filed 06/21/19 Page 1 of 3

1 ADAM A. REEVES (NYBN 2363877)
Attorney for the United States
2 Acting Under Authority Conferred By 28 U.S.C. § 515
3 HALLIE HOFFMAN (CABN 210020)
Chief, Criminal Division
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JEFF SCHENK (CABN 234355)
5 JOHN C. BOSTIC (CABN 264367)
ROBERT S. LEACH (CABN 196191)
6 Assistant United States Attorneys
150 Almaden Boulevard, Suite 900
San Jose, California 95113
Telephone: (408) 535-5061
Fax: (408) 535-5066
Jeffrey.b.schenk@usdoj.gov

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10 Attorneys for United States of America
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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UNITED STATES OF AMERICA,
Plaintiff,

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v.
ELIZABETH HOLMES and
RAMESH “SUNNY” BALWANI,

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Defendants.
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) CR-18-00258-EJD
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) JOINT STATUS MEMORANDUM
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The parties in the above-captioned matter hereby file this joint status memorandum in advance of

22 the trial setting conference set for June 28, 2019.
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I.

Trial Setting
The parties have met and conferred and believe that it is appropriate to set this matter for trial.

25 The government is prepared to commence trial at the Court’s direction. During our April 2019 status
26 conference, the government asked the Court to set the matter for trial recognizing that the complexity of
27 this case, including the volume of discovery, likely weighs in favor of a trial date in 2020. Although the
28 government went into discussions with defense counsel with a preference for a trial date during the first
JOINT STATUS MEMORANDUM
CR-18-00258 EJD

 Case 5:18-cr-00258-EJD Document 80 Filed 06/21/19 Page 2 of 3

1 half of 2020, the defense, particularly counsel for defendant Holmes, who did not represent Ms. Holmes
2 during the investigation that led to the indictment, explained to the government during those discussions
3 that significant work remains before it will be prepared for trial, including review of FDA/CMS
4 documents that have yet to be produced and approximately 4 terabytes of data recently produced to the
5 government that remains to be processed.
In light of each defendant’s need to prepare effectively for trial, the government does not oppose

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7 the defendants’ joint request for a trial in September 2020, or as soon thereafter as would be convenient
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The parties jointly ask this Court to reserve three months for trial. This three-month estimate

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10 includes time for jury selection, the government’s case-in-chief, and time for each defendant to present a
11 case, should either or both choose to make such a presentation.
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II.

Trial Scheduling Order
The parties have also met and conferred regarding a scheduling order. The parties propose that

14 they submit a jointly proposed scheduling order two weeks after this Court sets the matter for trial.
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16 DATED: June 21, 2019

Respectfully submitted,

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ADAM A. REEVES
Attorney for the United States
Acting Under Authority Conferred
By 28 U.S.C. § 515

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/s/
JEFF SCHENK
JOHN C. BOSTIC
ROBERT S. LEACH
Assistant United States Attorneys

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24 DATED: June 21, 2019
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/s/
KEVIN DOWNEY
LANCE WADE
Attorneys for Elizabeth Holmes

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JOINT STATUS MEMORANDUM
CR-18-00258 EJD

 Case 5:18-cr-00258-EJD Document 80 Filed 06/21/19 Page 3 of 3

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2 DATED: June 21, 2019
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/s/
JEFF COOPERSMITH
STEVE CAZARES
Attorneys for Ramesh “Sunny”
Balwani

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JOINT STATUS MEMORANDUM
CR-18-00258 EJD