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United States of America v. Jerry Ramirez

January 18, 2011

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



BENJAMIN B. WAGNER United States Attorney JOHN K. VINCENT Assistant U.S. Attorney 501 I Street, Suite 10-100 Sacramento, California 95814 Telephone: (916) 554-2700

MOTION TO CONTINUE STATUS CONFERENCE, STIPULATION, AND ) [PROPOSED] ORDER THEREON

Reasons for Motion to Continue The defense requests a continuance in the above-captioned case. DNA results were recently released, and the defense needs time to analyze those. In addition, the defense has information it has obtained through investigation which it wishes to share with the government. The defense requests that the status conference presently set for January 18, 2011 at 8:30 a.m. be continued to Monday, February 14, 2011 at 8:30 a.m.. The United States does not oppose this request for a continuance.

Stipulation

The parties, through their respective counsel, stipulate that the status conference presently set for January 18, 2011 at 8:30 a.m. be continued to Monday, February 14, 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. § 3161(h)(7)(B)(iv) for defense preparation and gathering of materials which may affect a possible plea negotiation. (Local Code T4).

Dated: January 13, 2011

ORDER GOOD CAUSE APPEARING, the calendaring change for a further status conference, as set forth above, with the stipulated exclusion of time under the Speedy Trial Act (18 U.S.C. § 3161) IS SO ORDERED.

20110118

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