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United States of America v. Alex Antonio Hernandez- Ramirez

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


March 29, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
ALEX ANTONIO HERNANDEZ- RAMIREZ,
DEFENDANT.

The opinion of the court was delivered by: Judge: Hon. Lawrence J. O'Neill

DANIEL J. BRODERICK, Bar #89424 Federal Defender ERIC V. KERSTEN, Bar #226429 Assistant Federal Defender Designated Counsel for Service 2300 Tulare Street, Suite 330 Fresno, California 93721-2226 Telephone: (559) 487-5561 Attorney for Defendant Alex Antonio Hernandez-Ramirez

STIPULATION TO CONTINUE STATUS CONFERENCE AND ORDER THEREON

Date: April 16, 2012

Time: 8:30 a.m.

IT IS HEREBY STIPULATED by and between the parties hereto through their respective counsel, IAN A. GARRIQUES, Assistant United States Attorney, counsel for plaintiff, and ERIC V. KERSTEN, Assistant Federal Defender, counsel for defendant Alex Antonio Hernandez-Ramirez, that the date for status conference in this matter may be continued to April 16, 2012, or the soonest date thereafter that is convenient to the court. The date currently set for status conference is April 2, 2012. The requested new date is April 16, 2012.

The government has extended a fast-track plea offer in this matter and Mr. Hernandez Ramirez has signed the offer. Hernandez-Ramirez has been advised of the USPO guideline calculations and he is aware of the anticipated sentence, but the full PSR has not yet been completed. This short continuance is requested to allow time for completion of the PSR, and time for counsel to review the PSR with Hernandez-Ramirez prior to entry of the plea and sentencing.

The parties agree that the delay resulting from the continuance shall be excluded as necessary for effective defense preparation pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv). For this reason, the ends of justice served by the granting of the requested continuance outweigh the interests of the public and the defendant in a speedy trial.

ORDER

Good cause has been stated for the continuance. The intervening period of delay is excluded in the interests of justice pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).

IT IS SO ORDERED.

Lawrence J. O'Neill UNITED STATES DISTRICT JUDGE

20120329

© 1992-2012 VersusLaw Inc.



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