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 September 17, 2012, to October 9, 2012, at 9:30 a.m.
2. Defense counsel has six, in-custody Preliminary Hearings scheduled on September 17, 2012 in Stanislaus County Superior Court and cannot be present in the above-captioned matter in Federal Court.
3. Further, defense counsel has not reviewed the presentencing report with Mr. Ramirez-Cardenas with a certified interpreter. As such, defense counsel requests the continuance in order to allow a complete review of the Report from Probation with the defendant, and to file the potential 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 September 17, 2012 through October 9, 2012, for defense preparation under 18 U.S.C. § 3161(h)(8)(B)(ii) and (iv).
Dated: September 13, 2012 /s/ Robert L. Forkner ROBERT L. FORKNER Attorney for Defendant VALENTIN RAMIREZ-CARDINAS Dated: September 13, 2012 BENJAMIN B. WAGNER United States Attorney by: /s/ Michael Beckwith MICHAEL BECKWITH Assistant U.S. Attorney 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-CARDENAS
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, Plaintiff, v. VALENTIN RAMIREZ-CARDINAS, Defendants.
ORDER TO CONTINUE SENTENCING
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