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United States of America v. Elias Alvarez Ramirez and Jose

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


January 31, 2011

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

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

AMENDED STIPULATION RE: 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 January 6, 2011, at 9:00 a.m. be vacated and the Status Conference be continued to this court's calendar on February 10, 2011 at 9:00 a.m. Additional time is needed for completion Mr. Elias Alvarez Ramirez's interview. Due to various calendar conflicts between attorneys and agents, Mr. Alvarez Ramirez's interview has had to be re- scheduled. Attorneys and agents are currently working to coordinate a new date for the interview.

The court is advised that counsel have conferred about this request that they have agreed to the court date of February 10, 2011 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 February 10, 2011.

Respectfully Submitted, Dated: January 3, 2011 Preciliano Martinez Attorney for Defendant ELIAS ALVAREZ RAMIREZ

Dated: January 3, 2011 Matthew Bockmon Attorney for Defendant JOSE RAMIREZ

Dated: January 3, 2011 Todd Leras Assistant U.S. Attorney

ORDER

Having read and considered the foregoing stipulation, IT IS THE ORDER of the Court that the current January 6, 2011 Status Conference hearing is hereby vacated and reset to February 10, 2011.

20110131

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