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United States of America v. Re: Elias Alvarez Ramirez and Jose Ramirez

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


November 30, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
RE: ELIAS ALVAREZ RAMIREZ AND JOSE RAMIREZ,
DEFENDANTS

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

PRECILIANO MARTINEZ ATTORNEY AT LAW State Bthar No. 93253 801 15 St, Suite F Modesto, CA 95354 (209)579-2206/ (209)579-2211 FaX Attorney for Defendant ELIAS ALVAREZ RAMIREZ

AMENDED STIPULATION CONTINUANCE AND ORDER

IT IS HEREBY STIPULATED by and between Assistant United States Todd Leras, Counsel for Plaintiff, Attorney Preciliano Martinez, Counsel for Defendant Elias Alvarez Ramirez and Attorney Matthew Bockmon, Counsel for Defendant Jose Ramirez, that the Status Conference date scheduled for December 2, 2010, at 9:00 a.m. be vacated and the Status Conference be continued to this court's calendar on December 16, 2010 at 9:00 a.m. Counsel for defense have a calendar conflict. The court is advised that counsel have conferred about thi s request that they have agreed to the court December 16, 2010 date and that Mr. Leras and Mr. Bockmon have authorized Preciliano Martinez to sign this stipulation on their behalf.

The parties agree and stipulate that time should be excluded under the Speedy Trial Act pursuant to Local Code T4 for completion of plea negotiations, up to and including December 16, 2010. Respectfully Submitted,

Dated: November 30, 2010 /s/ Preciliano Martinez

Dated: November 30, 2010 /s/ Matthew Bockmon

Dated: November 30, 2010 /s/

ORDER

Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current December 2, 2010 Status Conference hearing is hereby vacated and reset to December 16, 2010.

20101130

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