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.
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Jules F. Bonjour
Attorney for Raquel Ramirez
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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.
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HON. D. LOWELL JENSEN
United States District Judge