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govinfo:USCOURTS-caed-2_10-cr-00186-11

U.S. District Court for the Eastern District of California · 2011-08-26

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DANIEL J. BRODERICK, #89424
Federal Defender
DENNIS S. WAKS, BAR #142581 
Supervising Assistant Federal Defender
801 I Street, 3
rd Floor
Sacramento, California 95814
Telephone: (916) 498-5700
Attorney for Defendant
RAY RAMIREZ
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA, )
)
Plaintiff, )
)
v. )
)
RAY RAMIREZ, )
)
Defendant. )
______________________________
CR.S. 10-186-FCD
STIPULATION AND ORDER 
TO EXTEND TIME FOR STATUS 
CONFERENCE AND EXCLUDE TIME
DATE: October 17, 2011
Time: 10:00 a.m.
Judge: Frank C. Damrell, Jr. 
Defendant RAY RAMIREZ, by and through his counsel, DENNIS S.
WAKS, Supervising Assistant Federal Defender, and the United
States Government, by and through its counsel, JILL M. THOMAS,
Assistant United States Attorney, hereby stipulate that the
status conference set for September 6, 2011, be rescheduled for a
status conference on Monday, October 17, 2011, at 10:00 a.m. 
 This continuance is being requested because defense counsel
requires additional time to receive and review discovery, discuss
the case with the government, and pursue investigation. 
Furthermore, this defendant has some serious medical conditions
which effect his ability to assist counsel at the present time.
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 Speedy trial time is to be excluded from the date of this
order through the date of the status conference set for October
17, 2011, pursuant to 18 U.S.C. §3161(h)(7)(B)(iv) and Local Code
T4. [reasonable time to prepare]. 
DATED: August 26, 2011
Respectfully Submitted,
DANIEL J. BRODERICK
Federal Defender
/s/ Dennis S. Waks 
Supervising Assistant
Federal Defender
Attorney for Defendant
RAY RAMIREZ
DATED: August 26, 2011 BENJAMIN B. WAGNER
United States Attorney
/s/ Dennis S. Waks for 
JILL M. THOMAS
Assistant U.S. Attorney
IT IS SO ORDERED.
Dated: August 26, 2011
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