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United States of America v. Carlos Daniel Ramirez-Espinoza

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


September 20, 2011

UNITED STATES OF AMERICA, PLAINTIFF,
v.
CARLOS DANIEL RAMIREZ-ESPINOZA,
DEFENDANT.

The opinion of the court was delivered by: Oliver W. Wanger United States District Judge

Date: December 19, 2011

Time: 1:30 p.m.

Judge: TBD

STIPULATION TO CONTINUE STATUS CONFERENCE; ORDER

IT IS HEREBY STIPULATED by and between the parties through their respective counsel, Assistant United States Attorney Yashar Nilchian, Counsel for Plaintiff, and Assistant Federal Defender Peggy Sasso, Counsel for Defendant Carlos Daniel Ramirez-Espinoza, that the hearing currently set for September 26, 2011 at 9:00 a.m., may be rescheduled to December 19, 2011 at 1:30 p.m. and the schedule for filing of motions and for hearing thereon may be set as follows: Opening brief by November 14, 2011; Opposition brief by December 7, 2011; Reply by December 14, 2011. The revised hearing date is requested given that the Superior Court of California, County of San Joaquin moved the hearing on Mr. Ramirez-Espinoza's motion to vacate judgment in Case No. SF105250C from September 14, 2011 to October 12, 2011. It is anticipated that the Superior Court will issue its ruling on or shortly after the hearing.

The parties agree that the delay resulting from the continuance shall be excluded because the ends of justice served by continuing this case outweigh the best interests of the public and the defendant in a speedy trial in that additional time is necessary for effective defense preparation. 18 U.S.C. §§ 3161(h)(7)(A) and 3161(h)(7)(B)(iv).

BENJAMIN B. WAGNER United States Attorney Dated: September 20, 2011 /s/ Yashar Nilchian YASHAR NILCHIAN Special Assistant United States Attorney Attorney for Plaintiff DANIEL J. BRODERICK Federal Defender Dated: September 20, 2011 /s/ Peggy Sasso PEGGY SASSO Assistant Federal Defender Attorney for Defendant CARLOS DANIEL RAMIREZ-ESPINOZA

IT IS SO ORDERED.

20110920

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