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United States v. Ramirez-Guevara

June 15, 2010

UNITED STATES OF AMERICA, PLAINTIFF,
v.
MAXIMINO RAMIREZ-GUEVARA, DEFENDANT.



The opinion of the court was delivered by: Judge: Hon. Edward J. Garcia

STIPULATION AND [PROPOSED] ORDER

DATE: July 16, 2010

TIME: 10:00 a.m.

It is hereby stipulated and agreed to between the United States of America through MICHAEL ANDERSON, Assistant U.S. Attorney, and defendant, MAXIMINO RAMIREZ-GUEVARA, by and through his counsel, BENJAMIN GALLOWAY, Assistant Federal Defender, that the status conference set for Friday, June 18, 2010, be continued to Friday, July 16, 2010, at 10:00 a.m.

This continuance is being requested as counsel are working to resolve this case but need additional time to complete that process. Specifically, the defense just provided the government with substantial additional material in furtherance of settlement, which the government will need time to review and consider before extending an offer to Mr. Ramirez-Guevara.

Speedy trial time is to be excluded from the date of this order through the date of the status conference set for July 16, 2010, pursuant to 18 U.S.C. §§ 3161 (h)(7)(A)&(B)(iv) [reasonable time to prepare] (Local Code T4).

DATED: June 15, 2010

Respectfully submitted,

DANIEL J. BRODERICK Federal Defender

BENJAMIN GALLOWAY Assistant Federal Defender Attorney for Defendant MAXIMINO RAMIREZ-GUEVARA

DATED: June 15, 2010

BENJAMIN B. WAGNER United States Attorney

MICHAEL ANDERSON Assistant U.S. Attorney Attorney ...


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