USA v. Pope, et al.,

STIPULATION & ORDER CONTINUING JUDGMENT AND SENTENCING 1
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WILLIAM F. PORTANOVA, SBN 281364
400 Capitol Mall, Suite 1100
Sacramento, CA 95819
Telephone: (916) 444-7900
wfp@portanova.com
Attorney for Defendant
JESSE RAMIREZ
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
JESSE RAMIREZ,
Defendant.
CASE NO. 2:24-cr-0025-DC
STIPULATION AND ORDER CONTINUING
JUDGMENT AND SENTENCING
Date: January 16, 2026
Time: 9:30 a.m.
Court: Hon. Dena Coggins
Defendant, JESSE RAMIREZ, by and through his undersigned counsel, and Plaintiff United
States of America, by and through its undersigned counsel, hereby stipulate as follows:
1. This matter is set for judgment and sentencing on January 16, 2026. By this
stipulation, Defendant Jesse Ramirez moves to continue the judgment and sentencing
to Friday, April 3, 2026.
2. Mr. Ramirez pleaded guilty pursuant to plea agreement on October 3, 2025. The plea
agreement provided for a wide range for the loss calculation due to a dispute as to the
loss attributable to the defendant’s role in the conspiracy.
3. Probation Offier Hayley La Fazia issued a draft presentence report and provided it to
defense counsel on December 2, 2026.
4. Due to several factors, defense counsel requires additional time to research and present
Case 2:24-cr-00025-DC Document 75 Filed 01/06/26 Page 1 of 4

STIPULATION & ORDER CONTINUING JUDGMENT AND SENTENCING 2
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objections to the draft presentence report. Chief among the informal objections will be
the calculation of loss. Effective presentation of this objection requires a rigorous factual
and legal examination of the government’s calculation of loss.
5. This continuance of the sentencing date is required in order to afford defense counsel
additional time to continue to evaluate the recommendations and findings of the draft
Presentence Report and to evaluate legal and factual arguments and objections to the
contents thereof. Certain of this work was postponed due to the months-long freeze in
CJA payments and despite exercise of due diligence, the present sentencing date and
presentence briefing schedule do not all defense counsel sufficient time time to
effectively present Mr. Ramirez’s position to United States Probation and to this court.
6. Due to trial and other scheduling conflicts with the parties and Probation’s availalbity, the
next practicable date for sentencing is April 3, 2026.
7. Therefore, Mr. Ramirez respectfully requests that the present sentencing hearing and
briefing schedules be continued as follows:
Judgment and Sentencing Date: April 3, 2026
Reply or Statement of Non-Opposition: March 27, 2026
Formal Objections to the Presentence Report shall be filed
with the Court and served on the Probation Officer and
opposing counsel no later than: March 20, 2026
The Presentence Report shall be filed with the Court and
disclosed to counsel no later than: March 13, 2026
Counsel’s written objection to the Presentence Report
shall be delivered to the Probation Officer and opposing
counsel no later than: March 6, 2026
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Case 2:24-cr-00025-DC Document 75 Filed 01/06/26 Page 2 of 4

STIPULATION & ORDER CONTINUING JUDGMENT AND SENTENCING 3
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Dated: December 22, 2025 /s/ William F. Portanova
_________________________
WILLIAM F. PORTANOVA
Attorney for Defendant
JESSE RAMIREZ
Dated: December 22, 2025 ERIC GRANT
United States Attorney
/s/ Jessica Delaney
By: _______________________
JESSICA DELANEY
Assistant United States Attorney
(Per email authorization)
Case 2:24-cr-00025-DC Document 75 Filed 01/06/26 Page 3 of 4

STIPULATION & ORDER CONTINUING JUDGMENT AND SENTENCING 4
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ORDER
The court, having received, read and considered the parties’ stipulation as to Defendant
Jesse Ramirez, filed on January 5, 2026, and good cause appearing therefrom, GRANTS the
parties’ request to continue the sentencing hearing and adjust the related briefing schedule.
Accordingly, the Sentencing Hearing scheduled for January 16, 2026, is VACATED and RESET
for April 3, 2026 at 9:30 a.m. in Courtroom 10 before the Honorable Dena M. Coggins. It is
FURTHER ORDERED that the Presentence Investigation Report briefing schedule is
MODIFIED as follows: the parties’ informal objections shall be delivered to the Probation
Officer no later than March 6, 2026; the final Report shall be submitted no later than March 13,
2026; Formal Objections or any Motion for Correction shall be submitted no later than March
20, 2026; and Reply, or Statement of Non-Opposition shall be submitted no later than March 26,
2026 by 12:00 PM (Noon).
IT IS SO ORDERED.
Dated: January 5, 2026	___________________________
Dena Coggins
United States District Judge
Case 2:24-cr-00025-DC Document 75 Filed 01/06/26 Page 4 of 4