(HC) Ramirez v. Warden of the Golden State Annex Detention Facility et al

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JAN DAVID KAROWSKY
Attorney at Law
A Professional Corporation
California State Bar Number 53854
2701 Del Paso Road, Ste. 130-276
Sacramento, CA 95835-2305
KarowskyLaw@sbcglobal.net
(916) 402-8223
Attorney for Petitioner
Ludwin Edenilson Venture Ramirez
UNITED STATES DISTRICT COURT
IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA
Ludwin Edenilson Venture Ramirez,
Petitioner,
vs.
Warden of the Golden State Annex Detention
Facility, et. al.,
Respondents
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Case No. 1:25-cv-01775-DC-CKD
STIPULATION TO CONTINUE DATE
FOR THE FILING OF A BRIEFING
SCHEDULE AND [PROPOSED] ORDER
PROCEDURAL HISTORY
On December 8, 2025, Petitioner filed a Petition for Writ of Habeas Corpus to be
released from an ICE detention facility on bond pending the conclusion of his immigration court
proceedings. On December 31, 2025, attorney Jan Karowsky, was appointed to represent
Petitioner.
Case 1:25-cv-01775-DC-CKD Document 14 Filed 01/30/26 Page 1 of 4

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FACTS – DECLARATION OF JAN DAVID KAROWSKY
I, Jan David Karowsky, do hereby declare under penalty of perjury that the following is
true and correct and that anything alleged on information and belief, I believe to be true:
I need more time within which to continue to gather necessary information before I am
reasonably able to set a realistic briefing schedule.
Immediately upon my appointment, I began to try to contact Mr. Ramirez. When I called
the institution in which he is detained, no live operator has ever answered the call. I left a
number of voice mail messages requesting return calls to no avail. I ultimately was able to set up
what I expected to be a video conference with Mr. Ramirez. However, on January 20, 2026, the
date for the video conference, I received a phone call from the detention facility indicating the
call would only be audio, since their website had not included information needed for a video
call.
Mr. Ramirez only speaks Spanish. He was able to provide me with very limited
information but did give me his wife’s name and phone number, who speaks English. I spoke to
her and now have provided my investigator with additional information which he is pursuing.
On January 22, 2026, I received back the questionnaire I sent to Mr. Ramirez on January
5, 2026 and both I and my investigator are conducting further needed investigation based on the
limited information received from my client.
Mr. Ramirez provided me with the name of his immigration attorney. I have called that
firm and left messages for the last 3 days with no return call. I still need to pursue that
information.
Also, I need to speak directly to Mr. Ramirez. In that regard, I have just submitted a
request for funds for an interpreter/translator and will arrange a Zoom call with my client and the
translator when the funds have been approved.
Case 1:25-cv-01775-DC-CKD Document 14 Filed 01/30/26 Page 2 of 4

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Therefore, I am unable to set a realistic briefing schedule as the Court has ordered until I
have obtained the needed information or realistically can estimate the time needed to gather that
information and prepare the necessary pleadings.
I do hereby declare under penalty of perjury that the preceding is true and correct and that
anything alleged on information and belief, I believe to be true. Executed on January 29, 2026 at
Sacramento County, California.
/s/ Jan David Karowsky
I have met and conferred with AUSA Heiko Coppola, the AUSA assigned to this case,
and have explained all of the above to him. Based on my need to effectively represent Mr.
Ramirez, Mr. Coppola and I agree and stipulate that instead of filing a joint briefing schedule
within 14 days of the Court’s Order dated December 31, 2025 that said briefing schedule will not
need to be filed until on or before February 26, 2026.
IT IS SO STIPULATED.
DATED: January 29, 2026 	Respectfully submitted,
JAN DAVID KAROWSKY
Attorney at Law
A Professional Corporation
/s/ Jan David Karowsky
by
JAN DAVID KAROWSKY
Attorney for Petitioner
Ludwin Edenilson Venture Ramirez
Dated: January 29, 2026 	Respectfully submitted,
ERIC GRANT
United States Attorney
/s/ HEIKO COPPOLA
by
HEIKO COPPOLA
Assistant United States Attorney
Case 1:25-cv-01775-DC-CKD Document 14 Filed 01/30/26 Page 3 of 4

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[PROPOSED] O R D E R
GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that instead of both
counsel filing a joint briefing schedule within 14 days of the Court’s Order dated December 31,
2025, said briefing schedule will not need to be filed until on or before February 26, 2026.
Dated: January 30, 2026
8 rami1775.stip.0226
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
Case 1:25-cv-01775-DC-CKD Document 14 Filed 01/30/26 Page 4 of 4