govinfo:USCOURTS-caed-2_22-cr-00046-65

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ERIN J. RADEKIN, SBN 214964 
2012 H Street, Suite 200 
Sacramento, CA 95811 
Telephone:  (916) 504-3931 
Facsimile:   (916) 447-2988 
Email: erinjradekin@gmail.com 
 
Attorney for Defendant 
JESUS CISNEROS-SANCHEZ 
 
 
IN THE UNITED STATES DISTRICT COURT 
 
FOR THE EASTERN DISTRICT OF CALIFORNIA  
 
 SACRAMENTO DIVISION 
 
 
 
UNITED STATES OF AMERICA, 
 
                                             Plaintiff, 
 
 
                                     v. 
 
 
JESUS CISNEROS-SANCHEZ, 
 
                                              Defendant. 
 
 
CASE NO. 2:22-CR-00046-WBS-5 
 
 
STIPULATION AND ORDER VACATING 
SCHEDULE OF DISCLOSURE AND 
SENTENCING AND SETTING STATUS 
CONFERENCE 
   
 
 Plaintiff United States of America, by and through Assistant United States Attorney 
Roger Yang, and Defendant Jesus Cisneros-Sanchez, by and through his counsel, Erin J. 
Radekin, hereby stipulate and respectfully request as follows: 
 1. On August 24, 2026, Defendant entered a guilty plea to Count One of the Superseding 
Indictment. The Court accepted the plea and set sentencing for December 7, 2026, at 10:00 a.m. 
ECF No. 263. 
 2. On August 24, 2026, the Court issued a Schedule of Disclosure for the Presentence 
Investigation Report (“PSR”), establishing deadlines in advance of the December 7, 2026 
sentencing. ECF No. 264. 
Case 2:22-cr-00046-WBS     Document 283     Filed 10/05/26     Page 1 of 4
 
  
 
 
 
 
 
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 3. On September 10, 2026, the Court substituted Erin J. Radekin as retained counsel for 
Defendant in place of his former counsel, Nicholas F. Reyes. ECF Nos. 265, 266. 
 4. New counsel was retained to evaluate issues concerning Defendant’s guilty plea and its 
immigration consequences. In connection with the plea proceedings, Defendant learned that the 
offense to which he pleaded guilty constitutes an aggravated felony for immigration purposes, 
placing him at risk of removal from the United States and loss of his lawful permanent resident 
status. 
 5. Defendant intends to file a motion to withdraw his guilty plea based upon the 
immigration consequences of the plea. New counsel has ordered the transcript of the August 24, 
2026 change-of-plea hearing and requires the transcript to complete her review and prepare the 
anticipated motion. The transcript request was filed on September 10, 2026. ECF No. 267. 
 6. United States Probation Officer Julie Besabe has been informed that Defendant 
anticipates filing a motion to withdraw his guilty plea. In light of the anticipated motion, 
Probation has asked counsel to obtain an order addressing the existing Schedule of Disclosure so 
that Probation is not required to proceed under the current presentence investigation and 
disclosure deadlines while the anticipated motion is pending. 
 7. Under these circumstances, the parties agree that proceeding with preparation and 
disclosure of the PSR under the existing schedule would be premature and potentially 
unnecessary. The parties therefore agree that the Schedule of Disclosure should be vacated 
pending further order of the Court. 
 8. Accordingly, the parties stipulate and respectfully request that the Court: 
Case 2:22-cr-00046-WBS     Document 283     Filed 10/05/26     Page 2 of 4
 
  
 
 
 
 
 
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     a. Vacate the Schedule of Disclosure filed August 24, 2026 (ECF No. 264), 
including all deadlines contained therein; 
     b. Vacate the sentencing presently scheduled for December 7, 2026, at 10:00 a.m.; 
and 
    c. Retain December 7, 2026, at 10:00 a.m. on the Court’s calendar and convert that 
hearing to a status conference, at which time the parties may address the status of Defendant’s 
anticipated motion to withdraw his guilty plea and further scheduling. 
IT IS SO STIPULATED. 
Dated: October 1, 2026     ERIC GRANT 
        United States Attorney 
 
        By: /s/ Roger Yang   
        ROGER YANG 
        Assistant United States Attorney 
        Attorney for Plaintiff 
        UNITED STATES OF AMERICA 
 
 
Dated: October 1, 2026     LAW OFFICE OF ERIN J. RADEKIN 
 
        By: /s/ Erin J. Radekin  
        ERIN J. RADEKIN 
        Attorney for Defendant 
        JESUS CISNEROS-SANCHEZ 
 
ORDER 
 
 GOOD CAUSE APPEARING, based upon the stipulation of the parties, IT IS HEREBY 
ORDERED that: 
 1. The Schedule of Disclosure filed August 24, 2026 (ECF No. 264), including all 
deadlines contained therein, is VACATED; 
Case 2:22-cr-00046-WBS     Document 283     Filed 10/05/26     Page 3 of 4
 
  
 
 
 
 
 
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 2. The sentencing of Defendant Jesus Cisneros-Sanchez presently set for December 7, 
2026, at 10:00 a.m. is VACATED; and 
 3. A STATUS CONFERENCE is set for December 7, 2026, at 10:00 a.m. in Courtroom 5 
before Senior United States District Judge William B. Shubb. 
IT IS SO ORDERED. 
 
Dated:  October 5, 2026 
 
 
 
 
 
  
 
 
 
Case 2:22-cr-00046-WBS     Document 283     Filed 10/05/26     Page 4 of 4

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