Case: United States v. Ramirez

INDICTMENT Filed as to Jaime Hector Ramirez (1) count(s) 1. Offense occurred in Riverside. (mat) (Entered: 08/21/2025)

CASE SUMMARY filed by AUSA Stehent T. Merrill as to Defendant Jaime Hector Ramirez; defendants Year of Birth: 1979. (mat) (Entered: 08/21/2025)

GOVERNMENT'S NOTICE OF REQUEST FOR DETENTION filed by Plaintiff USA as to Defendant Jaime Hector Ramirez.(mat) (Entered: 08/21/2025)

ARREST WARRANT RETURNED Executed on 8/17/25 as to Defendant Jaime Hector Ramirez. (lmh) (Entered: 09/01/2025)

REPORT COMMENCING CRIMINAL ACTION as to Defendant Jaime Hector Ramirez; defendants Year of Birth: 1979; date of arrest: 8/17/2025 (ctr) (Entered: 09/03/2025)

MINUTES OF POST-INDICTMENT ARRAIGNMENT: held before Magistrate Judge David T. Bristow as to Defendant Jaime Hector Ramirez (1) Count 1. Court issues Order under Fed. R. Crim. P. 5(f) concerning prosecutor's disclosure obligations;see General Order 21-02 (written order). Defendant arraigned, states true name is the name on the Indictment. Defendant entered not guilty plea to all counts as charged. Attorney: Ayah Sarsour, Deputy Federal Public Defender present. Case assigned to Judge Sunshine Suzanne Sykes. Court orders bail set for Jaime Hector Ramirez (1) $10,000, SEE CONDITIONS ON BOND. Jury Trial set for 10/6/2025 09:00 AM before Judge Sunshine Suzanne Sykes. Pretrial Conference set for 9/19/2025 09:00 AM before Judge Sunshine Suzanne Sykes. Motion set for hearing on 9/19/2025 at 09:00 AM before Judge Sunshine Suzanne Sykes. Court Smart: 8/19/2025. (ctr) (Entered: 09/03/2025)

FINANCIAL AFFIDAVIT filed as to Defendant Jaime Hector Ramirez. (Not for Public View pursuant to the E-Government Act of 2002) (ctr) (cbr). (Entered: 09/03/2025)

ADVISEMENT OF STATUTORY & CONSTITUTIONAL RIGHTS filed by Defendant Jaime Hector Ramirez. (ctr) (Entered: 09/03/2025)

ASSERTION OF FIFTH AND SIXTH AMENDMENT RIGHTS filed by Defendant Jaime Hector Ramirez. (ctr) (Entered: 09/03/2025)

REDACTED AFFIDAVIT OF SURETIES (No Justification - Pursuant to Local Criminal Rule 46-5.2.8) in the amount of $10,000 by surety: Alexander Ramirez for Filed by Defendant Jaime Hector Ramirez (mba) (Entered: 09/09/2025)

SEALED UNREDACTED AFFIDAVIT OF SURETIES (No Justification - Pursuant to Local Criminal Rule 46-5.2.8) filed by Defendant Jaime Hector Ramirez re: Affidavit of Surety (No Justification)(CR-4) 23 (mba) (cbr). (Entered: 09/09/2025)

DECLARATION RE: PASSPORT filed by Defendant Jaime Hector Ramirez, declaring that I have never been issued any passport or other travel document by any country. I will not apply for a passport or other travel document during the pendency of this case. (mba) Modified on 9/23/2025 (mba). (Entered: 09/23/2025)

NOTICE OF APPEARANCE OR REASSIGNMENT of Deputy Public Defender James A Flynn on behalf of Defendant Jaime Hector Ramirez. Filed by Defendant Jaime Hector Ramirez. (Attorney James A Flynn added to party Jaime Hector Ramirez(pty:dft))(Flynn, James) (Entered: 08/27/2025)

NOTICE OF APPEARANCE of attorney Ayah A. Sarsour, (DFPD), appearing on behalf of Defendant Jaime Hector Ramirez, filed by Defendant Jaime Hector Ramirez. (Sarsour, Ayah) (Entered: 08/27/2025)

NOTICE OF MOTION AND MOTION TO DISMISS INDICTMENT AND TO DISQUALIFY Filed by Defendant Jaime Hector Ramirez. (Attachments: # 1 PROPOSED ORDER GRANTING MOTION TO DISMISS AND TO DISQUALIFY DOC 8.) (mat) (Entered: 08/29/2025)

1 PROPOSED ORDER GRANTING MOTION TO DISMISS AND TO DISQUALIFY DOC 8.

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DECLARATION of Counsel re MOTION to Dismiss and to Disqualify 10 filed by Defendant Jaime Hector Ramirez. (mat) (Entered: 08/29/2025)

UNOPPOSED EXPARTE APPLICATION TO FILE OVERSIZED MEMORANDUM AND TO SET BRIEFING SCHEDULE; DECLARATION OF COUNSEL, (mat) (Additional attachment(s) added on 8/29/2025: # 1 PROPOSED ORDER GRANTING EXPARTE APPLICATION TO FILE OVERSIZED MEMORANDUM AND TO SET BRIEFING SCHEDULE DOC 7) (mat). (Entered: 08/29/2025)

[STRICKEN PURSUANT TO #14] EX PARTE APPLICATION for Leave to File Excess Pages as to Motion to Dismiss and to Disqualify (Unopposed), EX PARTE APPLICATION for Order for to Set a Briefing Schedule (Unopposed) Filed by Defendant Jaime Hector Ramirez. (Attachments: # 1 Proposed Order) (Flynn, James) Modified on 9/3/2025 (twdb). (Entered: 08/29/2025)

[STRICKEN PURSUANT TO #14] NOTICE OF MOTION AND MOTION to Dismiss Case, NOTICE OF MOTION AND MOTION to Disqualify Counsel as to Bilal A. Essayli and His Supervisees Filed by Defendant Jaime Hector Ramirez. Motion set for hearing on 10/17/2025 at 09:00 AM before Judge Sunshine Suzanne Sykes. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Declaration of Counsel, # 4 Proposed Order) (Flynn, James) Modified on 9/3/2025 (twdb). (Entered: 08/29/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Declaration of Counsel

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4 Proposed Order

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NOTICE TO FILER OF DEFICIENCIES in Electronic Filed Document RE: EX PARTE APPLICATION for Leave to File Excess Pages as to Motion to Dismiss and to Disqualify (Unopposed) EX PARTE APPLICATION for Order for to Set a Briefing Schedule (Unopposed) 7, NOTICE OF MOTION AND MOTION to Dismiss Case NOTICE OF MOTION AND MOTION to Disqualify Counsel as to Bilal A. Essayli and His Supervisees 8 . The following error(s) was/were found: Documents filed on August 29, 2025 are duplicative of the documents filed on August 28, 2025. In response to this notice, the Court may: (1) order an amended or correct document to be filed; (2) order the document stricken; or (3) take other action as the Court deems appropriate. You need not take any action in response to this notice unless and until the Court directs you to do so. (iva) (Entered: 09/02/2025)

ORDER TO STRIKE ELECTRONICALLY FILED DOCUMENT(S) by Judge Sunshine Suzanne Sykes: the following document(s) be STRICKEN for failure to comply with the Local Rules, General Order and/or the Courts Case Management Order: EX PARTE APPLICATION 7, NOTICE OF MOTION AND MOTION to Dismiss Case 8, for the following reasons: Pursuant to the Notice to Filer of Deficiencies (Dkt. 13), the documents are hereby stricken. (twdb) (Entered: 09/03/2025)

STIPULATION to Continue TRIAL DATE from 10/6/2025 to 2/23/2026, STIPULATION re: excludable delay from 10/6/2025 to 2/23/2026 filed by Plaintiff USA as to Defendant Jaime Hector Ramirez (Attachments: # 1 Proposed Order)(Merrill, Stephen) (Entered: 09/03/2025)

ORDER CONTINUING TRIAL DATE AND FINDINGS REGARDING EXCLUDABLE TIME PERIODS PURSUANT TO SPEEDY TRIAL ACT by Judge Sunshine Suzanne Sykes, as to Defendant Jaime Hector Ramirez 15 . NOTE CHANGES MADE BY COURT. Trial continued to 2/23/2026 at 09:00 AM before Judge Sunshine Suzanne Sykes. Pretrial Conference continued to 2/6/2026 at 09:00 AM before Judge Sunshine Suzanne Sykes. (twdb) (Entered: 09/05/2025)

STANDING ORDER by Judge Sunshine Suzanne Sykes as to Defendant Jaime Hector Ramirez, (iva) (Entered: 09/08/2025)

ORDER OF THE CHIEF JUDGE 25-126 by Judge Dolly M. Gee as to Defendant Jaime Hector Ramirez. IT IS HEREBY ORDERED that all district judges of the United States District Court for the Central District of California shall be recused from hearing motions concerning the disqualification of Acting United States Attorney Bilal A. Essayli. FURTHER ORDERED that all motions concerning the disqualification of Acting United States Attorney Bilal A. Essayli shall be transferred to the Honorable J. Michael Seabright of the United States District Court for the District of Hawaii in accordance with the Honorable Mary H. Murguia's designation order. (jp) (Entered: 09/09/2025)

ORDER (U.S.C. § 292(b)) by Chief Circuit Judge Mary H. Murguia as to Defendant Jaime Hector Ramirez: Pursuant to 28 U.S.C. § 292(b), I hereby designate the Honorable Michael Seabright, United States Senior District Judge for the District of Hawaii, to temporarily perform the duties of United States District Judge on an as-needed basis for the Central District of California beginning on 9/8/2025, and ending on 12/31/2025, and for such additional time required in advance to prepare or thereafter to complete unfinished business. (jp) (Entered: 09/09/2025)

MEMORANDUM FOR RELEASE ORDER AUTHORIZATION filed by PSA Officer as to Defendant Jaime Hector Ramirez. Submitted in compliance with conditions as set forth in (mba) (Entered: 09/23/2025)

BOND AND CONDITIONS OF RELEASE filed as to Defendant Jaime Hector Ramirez conditions of release: SEE CONDITIONS ON BOND approved by Magistrate Judge David T. Bristow. (ctr) (Entered: 09/23/2025)

(IN CHAMBERS) ORDER by Chief Judge Dolly M. Gee as to Defendant Jaime Hector Ramirez. Pursuant to OCJ 25-126 25, the motion [Doc. 10 ] is transferred to the Honorable J. Michael Seabright for determination. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (dd) TEXT ONLY ENTRY (Entered: 09/10/2025)

WAIVER of Defendants Presence filed by Defendant Jaime Hector Ramirez (Sarsour, Ayah) (Entered: 09/10/2025)

ORDER OF THE CHIEF JUDGE 25-127 by Chief Judge Dolly M. Gee as to Defendant Jaime Hector Ramirez. IT IS HEREBY ORDERED that all magistrate judges of the United States District Court for the Central District of California shall be recused from assisting with motions relating to the disqualification of Acting United States Attorney Bilal A. Essayli. IT IS HEREBY ORDERED, with the concurrence of the Honorable Derrick Watson, Chief Judge, District of Hawaii, that the Honorable Barry M. Kurren, United States Magistrate Judge, District of Hawaii, is hereby designated to hold court and perform other judicial duties under 28 U.S.C. section 636, subsections (a), (b), and (c), in the Central District of California, beginning 9/10/2025 and ending on 12/31/2025. Pursuant to this designation, Magistrate Judge Kurren shall be assigned to assist the Honorable J. Michael Seabright with motions relating to the disqualification of Acting United States Attorney Bilal A. Essayli. (gk) (Entered: 09/10/2025)

(IN CHAMBERS) ORDER by Visiting Judge Michael Seabright as to Defendant Jaime Hector Ramirez. The Court sets a Zoom Status Conference re the Motions to Dismiss Indictment and Disqualify Counsel as to Bilal A. Essayli and His Supervisees 10 for September 11, 2025 at 11:30 a.m. Defendants' presence is not required for this hearing. The Court will use Chief Judge Dolly M. Gees Zoom link for the hearing. The Zoom information can be accessed at https://apps.cacd.uscourts.gov/Jps/honorable-dolly-m-gee.THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (dd) TEXT ONLY ENTRY (Entered: 09/10/2025)

MINUTES OF Zoom Status Conference held before Judge J. Michael Seabright as to Defendant Jaime Hector Ramirez RE: Motions to Dismiss Indictment and Disqualify Counsel as to Bilal A. Essayli and His Supervisees 10 . As stated on the record, defense counsel orally waives their clients presence at the hearing. The Court and counsel confer regarding the Motions to Dismiss Indictment and Disqualify Counsel as to Bilal A. Essayli and His Supervisees. The Court sets the following dates: The Government's responses are due no later than 9/19/2025. Defendants' replies are due no later than 9/26/2025. The Court sets a hearing on the Motions for 10/14/2025 at 01:30 PM before Judge John M. Seabright, in a courtroom to be determined at a later time. Counsel are reminded to serve the any documents relating to these motions to the Courtroom Deputy Clerk at DMG_Chambers@cacd.uscourts.gov. Court Reporter: Sharon Seffens. (gk) (Entered: 09/11/2025)

MINUTES OF IN CHAMBERS ORDER by Judge J. Michael Seabright as to Defendant Jaime Hector Ramirez. Prior to re-assignment of the pending Motions to Dismiss Indictments and to Disqualify, Defendants had filed Unopposed Ex Parte Applications to File Oversized Memoranda and to Set Briefing Schedules 9 . Those Ex Parte Applications are GRANTED as to filing of oversized memoranda and are MOOT as to the proposed briefing schedules. The Government's Opposition Memoranda to the Motions to Dismiss Indictments and to Disqualify may also exceed page limits, but are LIMITED to 13,319 words (the length of the memorandum in Garcia). Any Reply memoranda are limited to 7,000 words. (gk) (Entered: 09/17/2025)

MEMORANDUM in Opposition to NOTICE OF MOTION AND MOTION for Order for 10 filed by Plaintiff USA as to Defendant Jaime Hector Ramirez. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4)(Robbins, Alexander) (Entered: 09/19/2025)

1 Exhibit 1

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2 Exhibit 2

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3 Exhibit 3

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4 Exhibit 4

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EX PARTE APPLICATION for Leave to File Excess Pages as to Reply in Support of Motion to Dismiss and Disqualify (Unopposed) Filed by Defendant Jaime Hector Ramirez. (Attachments: # 1 Proposed Order) (Flynn, James) (Entered: 09/26/2025)

REPLY in Support of NOTICE OF MOTION AND MOTION for Order for 10 filed by Defendant Jaime Hector Ramirez. (Flynn, James) (Entered: 09/26/2025)

(IN CHAMBERS) ORDER by Judge J. Michael Seabright as to Defendant Jaime Hector Ramirez. For good cause shown, the Unopposed Ex Parte Application to File Oversized Reply, [ECF No. 37 ], is GRANTED for both United States v. Garcia, Case No. 2:25-cr-655-MEMF, and United States v. Ramirez, Case No. 5:25-cr-264-SSS. THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (dd) TEXT ONLY ENTRY (Entered: 09/29/2025)

JOINT NOTICE OF RELATED DECISION re NOTICE OF MOTION AND MOTION for Order for 10 filed by Defendant Jaime Hector Ramirez. (Attachments: # 1 Exhibit District of Nevada Order)(Flynn, James) (Entered: 10/06/2025)

UNOPPOSED MOTION for Leave to File Amicus Curiae Brief by Bipartisan Group of Current and Former Members of Congress filed by Movants Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett as to Defendant Jaime Hector Ramirez. (Attachments: # 1 Lodged Brief) (gk) (Entered: 10/10/2025)

1 Lodged Brief

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APPLICATION of Non-Resident Attorney Carey R. Dunne to Appear Pro Hac Vice on behalf of Movants Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett as to Defendant Jaime Hector Ramirez. (Pro Hac Vice Fee - Not Paid) (Attachments: # 1 Proposed Order) (gk) (Entered: 10/10/2025)

APPLICATION of Non-Resident Attorney Monica P. Folch to Appear Pro Hac Vice on behalf of Movants Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett as to Defendant Jaime Hector Ramirez. (Pro Hac Vice Fee - Not Paid) (Attachments: # 1 Proposed Order) (gk) (Entered: 10/10/2025)

BRIEF of Amici Curiae Bipartisan Current and Former Members of Congress in Support of Neither Party, Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett as to Defendant Jaime Hector Ramirez. (gk) (Entered: 10/28/2025)

MINUTES OF Motion Hearing held before Judge J. Michael Seabright as to Defendant Jaime Hector Ramirez RE: Motions to Dismiss Indictment and Disqualify Counsel as to Bilal A. Essayli and His Supervisees 10 . As stated on the record, defense counsel orally waive their clients' presence at the hearing. The Court and counsel confer regarding the Motions to Dismiss Indictment and Disqualify Counsel as to Bilal A. Essayli and His Supervisees. The Court takes the motions under submission. The Court sets the following date: Simultaneous briefing as to the issue stated on the record are due no later than Thursday, 10/16/2025. Counsel are reminded to serve the any documents relating to these motions to the Courtroom Deputy Clerk. Court Smart: CS 10/14/2025. (gk) (Entered: 10/14/2025)

ORDER ON APPLICATION OF NONRESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE by Judge J. Michael Seabright: granting 42 Non-Resident Attorney Carey R. Dunne APPLICATION to Appear Pro Hac Vice on behalf of Movants Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett, designating Matthew Seligman as local counsel. Adding Attorney Carey R. Dunne for Nydia Velazquez,Carey R. Dunne for Bennie Thompson,Carey R. Dunne for Frank Pallone,Carey R. Dunne for Stephen Lynch,Carey R. Dunne for Wayne Gilchrest,Carey R. Dunne for Lloyd Doggett. as to Jaime Hector Ramirez (1) (chk) (Entered: 10/23/2025)

ORDER ON APPLICATION OF NONRESIDENT ATTORNEY TO APPEAR IN A SPECIFIC CASE PRO HAC VICE vy Judge J. Michael Seabright: granting 43 Non-Resident Attorney Monica P. Folch APPLICATION to Appear Pro Hac Vice on behalf of Movants Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett, designating Matthew Seligman as local counsel. Adding Attorney Monica P. Folch for Nydia Velazquez,Monica P. Folch for Bennie Thompson,Monica P. Folch for Frank Pallone,Monica P. Folch for Stephen Lynch,Monica P. Folch for Wayne Gilchrest,Monica P. Folch for Lloyd Doggett. as to Jaime Hector Ramirez (1) (chk) (Entered: 10/23/2025)

TRANSCRIPT ORDER as to Defendant Jaime Hector Ramirez DCN number: PENDING for Court Smart (CS). Order for: Criminal Non Appeal.(Robbins, Alexander) (Entered: 10/15/2025)

TRANSCRIPT ORDER as to Defendant Jaime Hector Ramirez for Court Smart (CS). Order for: Criminal Non Appeal. (Attachments: # 1 Public Voucher)(Flynn, James) (Entered: 10/15/2025)

TRANSCRIPT filed as to Defendant Jaime Hector Ramirez for proceedings held on 10/14/25 1:36 p.m. to 3:32 p.m.. Court Reporter/Electronic Court Recorder: EXCEPTIONAL REPORTING SERVICES, INC., phone number (361) 949-2988. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Electronic Court Recorder before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Notice of Intent to Redact due within 7 days of this date. Redaction Request due 11/6/2025. Redacted Transcript Deadline set for 11/17/2025. Release of Transcript Restriction set for 1/14/2026.(apr) (Entered: 10/16/2025)

NOTICE OF FILING TRANSCRIPT filed as to Defendant Jaime Hector Ramirez for proceedings 10/14/25 1:36 p.m. to 3:32 p.m. re Transcript 47 THERE IS NO PDF DOCUMENT ASSOCIATED WITH THIS ENTRY. (apr) TEXT ONLY ENTRY (Entered: 10/16/2025)

SUPPLEMENT to NOTICE OF MOTION AND MOTION for Order for 10 filed by Defendant Jaime Hector Ramirez. (Flynn, James) (Entered: 10/16/2025)

SUPPLEMENTAL MEMORANDUM re NOTICE OF MOTION AND MOTION for Order for 10 filed by Plaintiff USA as to Defendant Jaime Hector Ramirez. (Robbins, Alexander) (Entered: 10/16/2025)

FINANCIAL ENTRY as to Defendant Jaime Hector Ramirez: Received $500.00 from Stris & Maher, LLP/ Monica P. Folch. Re: APPLICATION of Non-Resident Attorney Monica P. Folch to Appear Pro Hac Vice on behalf of Plaintiff Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett (Pro Hac Vice Fee - Not Paid) 43 . Receipt number 36758. (fa) (Entered: 10/23/2025)

FINANCIAL ENTRY as to Defendant Jaime Hector Ramirez: Received $500.00 from Stris & Maher, LLP./ Carey R. Dunne. Re: APPLICATION of Non-Resident Attorney Carey R. Dunne to Appear Pro Hac Vice on behalf of Plaintiff Nydia Velazquez, Bennie Thompson, Frank Pallone, Stephen Lynch, Wayne Gilchrest, Lloyd Doggett (Pro Hac Vice Fee - Not Paid) 42 . Receipt number 36759. (fa) (Entered: 10/23/2025)

ORDER GRANTING IN PART AND DENYING IN PART DEFENDANTS' MOTIONS TO DISMISS INDICTMENTS AND TO DISQUALIFY 10 by Judge J. Michael Seabright as to Defendant Jaime Hector Ramirez. This consolidated order resolves three motions to dismiss indictments and to disqualify Bilal A. Essayli as Acting United States Attorney. The motions were brought in three pending criminal cases by Defendants Jaime Hector Ramirez ("Ramirez") (Case No. 5:25-cr-264-SSS); Ismael Garcia, Jr. ("Garcia") (Case No. 2:25-cr-655-MEMF); and Ronny Rojas ("Rojas") (Case No. 2:22-cr-00573-FWS) (collectively, "Defendants"). In both Ramirez and Garcia, two substantively identical motions to dismiss appear on the docket. See Ramirez, ECF Nos. 8, 10 ; Garcia, ECF Nos. 21, 32. For purposes of this Order, the operative motions are Ramirez, ECF No. 10, and Garcia, ECF No. 21. The Unopposed Motion for Leave to File Amicus Brief filed by a "Bipartisan Group of Current and Former Members of Congress," Ramirez, ECF No. 41, is GRANTED. The brief, Ramirez, ECF No. 41-1, is deemed filed on 10/10/2025. Essayli unlawfully assumed the role of Acting United States Attorney for the Central District of California. He has been unlawfully serving in that capacity since his resignation from the interim role on 7/29/2025. Essayli may not perform the functions and duties of the United States Attorney as Acting United States Attorney. He is disqualified from serving in that role. For the reasons stated, however, the court does not dismiss Defendants' indictments, as they were lawfully signed by other attorneys for the government and there has been no showing of due process violations or other irregularities in Defendants' prosecutions resulting from Essayli's unlawful service as Acting United States Attorney. Moreover, Essayli remains the FAUSA and may perform the functions and duties of that office. See document for further details. (gk) Modified on 10/28/2025 (gk). (Entered: 10/28/2025)