Opinion
CR 19-0002 JAM
07-01-2021
UNITED STATES, Plaintiff, v. SALVADOR JESUS RAMIREZ, and SUSAN DANE COSTORIO CASILLAS, Defendants.
Daniel B. Olmos (CA SBN 235319) NOLAN BARTON & OLMOS LLP Counsel for Defendant Salvador Jesus Ramirez PHILLIP A. TALBERT Acting United States Attorney By: Heiko Coppola Assistant United States Attorney NOLAN BARTON & OLMOS LLP Daniel B. Olmos Attorney for Defendant Salvador Jesus Ramirez
Daniel B. Olmos (CA SBN 235319) NOLAN BARTON & OLMOS LLP Counsel for Defendant Salvador Jesus Ramirez
PHILLIP A. TALBERT Acting United States Attorney By: Heiko Coppola Assistant United States Attorney
NOLAN BARTON & OLMOS LLP Daniel B. Olmos Attorney for Defendant Salvador Jesus Ramirez
STIPULATION AND ORDER TO CONTINUE STATUS HEARING
THE HONORABLE JOHN A. MENDEZ UNITED STATES DISTRICT COURT JUDGE
IT IS HEREBY STIPULATED AND AGREED between the Government, through Assistant United States Attorney Heiko Coppola, and Defendants Salvador Jesus Ramirez and Susan Dane Costorio Casillas, through their undersigned counsel, that the status hearing in this matter be continued from July 6, 2021, to September 28, 2021, to permit defense counsel to continue reviewing discovery and preparing their defense. Further, undersigned counsel for Defendant Salvador Ramirez has informed counsel for the Government that he intends to provide discovery in the coming weeks, and the Government will need time to consider it. The parties last appeared for status on May 4, 2021, and informed the Court of their progress in this matter.
The parties further agree and request that the Court order, for the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., within which the trial of this case must commence, that the time period between July 6, 2021, to and including the September 28, 2021, status hearing, be excluded pursuant to 18 U.S.C. § 3161(h)(7)(A) and B(iv) and Local Code T4 to allow defense counsel reasonable time to prepare their clients' defense. The parties also stipulate that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial.
For the foregoing reasons, the parties stipulate to continue the status conference to September 28, 2021, at 9:30 a.m.
IT IS SO STIPULATED.
ORDER TO CONTINUE STATUS HEARING
GOOD CAUSE HAVING BEEN SHOWN, and pursuant to stipulation by the parties, it is hereby ordered that the status hearing for Defendants Salvador Jesus Ramirez and Susan Dane Costorio Casillas be continued to September 28, 2021, at 9:30 a.m. It is further ordered that, for the purpose of computing time under the Speedy Trial Act, 18 U.S.C. § 3161, et seq., the time period between July 6, 2021, to and including the September 28, 2021, status hearing be excluded pursuant to 18 U.S.C. § 3161(h)(7)(A) and B(iv) and Local Code T4. The Court finds that the ends of justice served by granting this continuance outweigh the best interests of the public and the defendant in a speedy trial.