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United States v. Alvarez Ramirez

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


September 9, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
ELIAS ALVAREZ RAMIREZ, JOSE RAMIREZ, TELFILO LUNA DELGADO, ADRIAN NEGRETE ANDRADE, FRANCISCO RAMIREZ SANCHEZ, JORGE LUIS CORONA RAMIREZ, ANTONIO RAMIREZ SANCHEZ, AND MIGUEL CORONA LOZANO, DEFENDANTS.

The opinion of the court was delivered by: Morrison C. England, Jr. United States District Judge

STIPULATION AND ORDER CONTINUING STATUS CONFERENCE

IT IS HEREBY STIPULATED by and between Plaintiff United States of America, by and through United States Attorney Lawrence G. Brown and Assistant U.S. Attorney Todd D. Leras, Attorney Preciliano Martinez as Counsel for Defendant Elias Alvarez Ramirez, Attorney William Feldman as Counsel for Defendant Jose Ramirez, Attorney Jeff Goodwin as Counsel for Defendant Telfilo Luna Delgado, Attorney Fred Dawson as Counsel for Defendant Adrian Negrete Andrade, Attorney Dina Santos as Counsel for Defendant Francisco Ramirez Sanchez, Attorney Erin Radekin as Counsel for Defendant Jorge Luis Corona Ramirez, Attorney Charles Bauer as Counsel for Defendant Antonio Ramirez Sanchez and Attorney Gilbert Roque as Counsel for Defendant Miguel Corona Lozano, that the status conference scheduled for September 10, 2009, be continued to October 15, 2009, at 9:00 a.m.

The request to continue the status conference is made on the ground that the government has conducted additional investigation and plans to provide supplemental discovery to defense counsel. Some defense counsel and investigators have recently inspected real property involved in this case and plan to share their observations with other defense counsel. All defense counsel believe that they need time to review the additional discovery, share observations regarding the real property and to discuss these matters with their respective clients.

In addition to the matters mentioned in the previous paragraph, Attorney Jeff Goodwin is awaiting a supplemental report that will dispose of this matter for his client, Teofilo Luna Delgado. Attorney Erin Radekin is requesting that the government prepare a plea agreement for her client, Jorge Luis Corona Ramirez.

In light of the above circumstances, the government and all defendants agree that an exclusion of time is appropriate under 18 U.S.C. § 3161(h)(7)(B)(iv); Local Code T4 (reasonable time to prepare). All defense attorneys agree to this request and have authorized Assistant United States Attorney Todd D. Leras to sign this stipulation on their behalf.

DATED: September 9, 2009

TODD D. LERAS Assistant U.S. Attorney

By: Todd D. Leras for PRECILIANO MARTINEZ Attorney for Defendant ELIAS ALVAREZ RAMIREZ

By: Todd D. Leras for WILLIAM FELDMAN Attorney for Defendant JOSE RAMIREZ

By: Todd D. Leras for JEFF GOODWIN Attorney for Defendant TELFILO LUNA DELGADO

By: Todd D. Leras for FRED DAWSON Attorney for Defendant ADRIAN NEGRETE ANDRADE

By: Todd D. Leras for DINA SANTOS Attorney for Defendant FRANCISCO RAMIREZ SANCHEZ

By: Todd D. Leras for ERIN RADEKIN Attorney for Defendant JORGE LUIS CORONA RAMIREZ

By: Todd D. Leras for CHARLES BAUER Attorney for Defendant ANTONIO RAMIREZ SANCHEZ

By: Todd D. Leras for GILBERT ROQUE Attorney for Defendant MIGUEL CORONA LOZANO

IT IS HEREBY ORDERED:

1. The status conference set for September 10, 2009 is continued to October 15, 2009, at 9:00 a.m.

2. Based on the stipulations and representations of the parties, the Court finds that the ends of justice outweigh the best interest of the public and Defendants in a speedy trial. Accordingly, time under the Speedy Trial Act shall be excluded under 18 U.S.C. § 3161(h)(7)(B)(iv) and Local Code T4 (reasonable time to prepare) up to and including October 15, 2009.

IT IS SO ORDERED.

20090909

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