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United States of America v. Jerry Ramirez

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


December 3, 2010

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
JERRY RAMIREZ,
DEFENDANT.

STIPULATION AND [PROPOSED] ORDER CONTINUING STATUS

CONFERENCE

REASONS FOR REQUEST

The defense is in the process of a fairly complex investigation into this matter and both the government and the defense are awaiting the results of the DNA testing ordered at the last hearing which will be available sometime near the end of December. The parties are in agreement and request a continuance of the status conference, presently set for Monday, December 6, at 8:30 a.m., to Tuesday (Monday is a holiday) January 18, 2011 at 8:30 a.m. before the honorable William B. Shubb, U.S. District Court Judge presiding.

STIPULATION

For the reasons set forth above, it is hereby stipulated by and between the parties hereto through their respective counsel that the status conference presently scheduled for Monday, December 6, 2010 at 8:30 a.m. be continued to Tuesday, January 18, 2011 at 8:30 a.m.

The parties further stipulate that all time included in this continuance be excluded under the Speedy Trial Act, pursuant to 18 U.S.C. Section 3161(h)(8)(B)(ii)(Local Codes T2 and T4) through January 18, 2010 on the ground that the case is unusual and complex within the meaning of the Speedy Trial Act and for defense preparation and gathering of materials which may affect a possible plea negotiation for reasons described above, all pursuant to 18 U.S.C. Section 3161(h)(8)(B)(ii) and (iv)(Local Codes T2 and T4).

Dated: December 2, 2010

/s/ Mr. John Vincent, Esq. (by RMH) Assistant United States Attorney Counsel the United States /s/ Mr. Robert M. Holley, Esq. MR. ROBERT M. HOLLEY, Esq. Counsel for Mr. Ramirez

ORDER

GOOD CAUSE APPEARING, the above calendaring change with respect to "further status conference" as set forth above with the stipulated exclusion of time under the Federal Speedy Trial Act IS SO ORDERED.

20101203

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