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United States of America v. Valentin

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


June 4, 2012

UNITED STATES OF AMERICA, PLAINTIFF,
v.
VALENTIN RAMIREZ-CARDINEZ, DEFENDANTS.

ROBERT L. FORKNER (CSB# 166097) Law Offices of Robert L. Forkner 722 Thirteenth Street Modesto, CA 95354 Telephone: (209)544-0200 Fax: (209)544-1860 Attorney for Defendant, VALENTIN RAMIREZ-CARDINEZ

STIPULATION AND (PROPOSED)ORDER FOR CONTINUANCE OF SENTENCING

Defendant, VALENTIN RAMIREZ-CARDINEZ, through his attorney ROBERT L. FORKNER, together with the United States of America through its undersigned counsel, MICHAEL M. BECKWITH, Assistant United States Attorney, hereby stipulate and request the following:

1. That the Court continue the sentencing in the above- captioned case from June 4, 2012, to August 6, 2012, at 9:30 a.m.

2. As of this date, counsel has not received a presentencing report on Mr. Ramirez-Cardenas from the U.S. Probation officer. As such, defense counsel requests the continuance in order to permit the preparation of the Pre Sentencing Report; to allow a complete review of the Report from Probation with the defendant, and to file the necessary objections before the currently scheduled date.

For these reasons, the parties stipulate and request that the Court exclude time within which the trial must commence under the Speedy Trial Act from June 4, 2012 through August 6, 2012, for defense preparation under 18 U.S.C. § 3161(h)(8)(B)(ii) and (iv).

IT IS SO STIPULATED.

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

UNITED STATES OF AMERICA, Plaintiff, v. VALENTIN RAMIREZ-CARDINAS, Defendants.

CR. No. 09-380-WBS

ORDER TO CONTINUE SENTENCING

IT IS SO ORDERED.

20120604

© 1992-2012 VersusLaw Inc.



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