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United States v. Ramirez

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Mar 20, 2013
No.: CR 12-00465 DLJ (N.D. Cal. Mar. 20, 2013)

Opinion

No.: CR 12-00465 DLJ

03-20-2013

UNITED STATES OF AMERICA, Plaintiff, v. RAQUEL RAMIREZ, et.al., Defendant.

Jules F. Bonjour Attorney for Raquel Ramirez Dan Kaleba, AUSA Attorney for the United States


Jules F. Bonjour, State Bar No. 38980
BONJOUR, THORMAN, BARAY & BILLINGSLEY
24301 Southland Dr., Suite 312
Hayward, CA 94545
Tel: (510) 785-8400
Fax: (510) 670-0955
jules@btbandb.com
Attorneys for defendant Raquel Ramirez

STIPULATION AND [PROPOSED]

ORDER TO CONTINUE

HEARING DATE FROM MARCH

21, 2013 TO APRIL 18, 2013; AND

REQUEST TO TRAVEL


Date: March 21, 2013

Court: Hon. D. Lowell Jensen

The above-referenced matter is set for status hearing before this Court on March 21, 2013 at 9:00 a.m. The parties jointly request that the matter be continued from March 21, 2013 to April 18, 2013. The reason for the continuance is that the parties are close to reaching an agreement on a plea and need some additional time to finalize it. The parties further request that the Court exclude time under the Speedy Trial Act between March 21, 2013 and April 18, 2013 pursuant to 18 U.S.C. §§ 3161(h)(7)(A) and (B)(iv).

In addition Ms. Ramirez is requesting that she be allowed to leave the Northern District and travel to AnaMaria Island, Florida from April 6, 2013 to April 13, 2013 for a family reunion. Neither the government nor pretrial services, who have been contacted, have an objection to this request. IT IS SO STIPULATED.

____________

Jules F. Bonjour

Attorney for Raquel Ramirez

____________

Dan Kaleba, AUSA

Attorney for the United States

[PROPOSED] ORDER

Pursuant to stipulation of the parties and GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that the hearing in this matter is continued from March 21, 2013 to April 18, 2013 at 2:00 p.m. before this Court, and that time between March 21, 2013 and April 18, 2013 is excluded under the Speedy Trial Act. It is FURTHER ORDERED that the defendant be allowed to travel to AnaMaria Island, Florida from April 6, 2013 to April 13, 2013. IT IS SO ORDERED.

____________

HON. D. LOWELL JENSEN

United States District Judge


Summaries of

United States v. Ramirez

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
Mar 20, 2013
No.: CR 12-00465 DLJ (N.D. Cal. Mar. 20, 2013)
Case details for

United States v. Ramirez

Case Details

Full title:UNITED STATES OF AMERICA, Plaintiff, v. RAQUEL RAMIREZ, et.al., Defendant.

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION

Date published: Mar 20, 2013

Citations

No.: CR 12-00465 DLJ (N.D. Cal. Mar. 20, 2013)