USA v. Cortez et al

STIPULATION AND ORDER TO CONTINUE MOTION HEARING 1
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Law Office of Adam Pennella
Adam Pennella, SBN 246260
420 Third Street, Suite 250
Oakland, CA 94607
P. (510) 451-4600
F. (510) 451-3002
adam@avplawoffice.com
Counsel for Defendant
ANGEL RAMIREZ
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
vs.
AUSENCIO ALVAREZ CORTEZ,
ANGEL ISMAEL RAMIREZ,
Defendants
Case No.: 2:20-CR-00229 DC
STIPULATION AND ORDER TO
CONTINUE MOTION HEARING
DATE
It is hereby stipulated by and between counsel for the United States and counsel for the
Defendants Ausencio Cortez and Angel Ramirez that the motion hearing scheduled for October
23, 2026 at 9:30 a.m. be continued to December 4, 2026 at 9:30 a.m.1 The continuance is
requested because defense counsel recently suffered a new injury requiring surgery. As a result
of that injury, counsel is required to be non-weight bearing on one leg through sometime in
November, 2026, making travel and appearing in court onerous. The parties further stipulate and
agree that defense counsel’s reply to the government’s opposition may be delayed until October
12, 2026. Time was previously ordered excluded due to the trial that is set for February 16,
1 The only motion pending is one that was filed by Defendant Ramirez. However, counsel for Defendant Cortez
confirms via this stipulation that Mr. Cortez stipulates to the request to reset the motion hearing date.
Case 2:20-cr-00229-DC Document 90 Filed 10/08/26 Page 1 of 3

STIPULATION AND ORDER TO CONTINUE MOTION HEARING 2
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2027.
SO STIPULATED.
Eric Grant
United States Attorney
Dated: October 6, 2026 /s/ James Conolly
James Conolly
Assistant United States Attorney
Dated: October 6, 2026 /s/ Dina Santos
Dina Santos
Attorney for Ausencio Alvarez Cortez
Dated: October 6, 2026 /s/ Adam Pennella
Adam Pennella
Attorney for Angel Ismael Ramirez
Case 2:20-cr-00229-DC Document 90 Filed 10/08/26 Page 2 of 3

STIPULATION AND ORDER TO CONTINUE MOTION HEARING 3
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ORDER
IT IS HEREBY ORDERED as to Angel Ismael Ramirez, the court, having received, read
and considered the parties’ Stipulation filed on October 6, 2026 (Doc. No. 89), and good cause
appearing therefrom, APPROVES the parties’ request as to scheduling. Accordingly, the Motion
Hearing as to Defendant’s Motion for Relief (Doc. 83) set for October 23, 2026 is VACATED
and RESET for December 4, 2026 at 9:30 a.m. before the Honorable Dena M. Coggins, and
Defendant’s reply shall be filed by October 12, 2026.
IT IS SO ORDERED.
Dated: October 8, 2026	___________________________
Dena Coggins
United States District Judge
Case 2:20-cr-00229-DC Document 90 Filed 10/08/26 Page 3 of 3