(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 WITH COUNTRY
OF ORIGIN
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 12 Filed 01/09/26 Page 1 of 3

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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 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 have left a
number of voice mail messages requesting return calls to no avail. I have tried to set up a video
conference with Mr. Ramirez, but do not know the country from which he originates – thus
making it procedurally impossible to set up such a call.
I do know he had an immigration hearing set for January 6, 2026 but do not its outcome
or whether he has an immigration attorney representing him.
Therefore, I have written a letter to him, explaining who I am and my anticipated
representation. I have also included an extensive questionnaire, asking relevant questions. I
have provided both documents to him in English and Spanish also with a stamped, self-addressed
return envelope. I was only able to mail these to him on January 5, 2026.
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 6, 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.
Case 1:25-cv-01775-DC-CKD Document 12 Filed 01/09/26 Page 2 of 3

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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 6, 2026.
IT IS SO STIPULATED.
DATED: January 8, 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 8, 2026 	Respectfully submitted,
ERIC GRANT
United States Attorney
/s/ HEIKO COPPOLA
by
HEIKO COPPOLA
Assistant United States Attorney
[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 6, 2026. The
Court further notes the country of origin for ICE search purposes is El Salvador.
Dated: January 08, 2026
8 rami1775.stipmc
_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE
Case 1:25-cv-01775-DC-CKD Document 12 Filed 01/09/26 Page 3 of 3