Opinion
John R. Manning, Attorney at Law, Sacramento, CA, Attorney for Defendant, CYNTHIA CORN.
DEFENDANT'S MOTION TO MODIFY TURN IN DATE AND PROPOSED ORDER
WILLIAM B. SHUBB, District Judge.
Counsel for defendant Cynthia Corn, John R. Manning, Esq., hereby respectfully asks the court to modify and extend Ms. Corn's self surrender date from March 5, 2015 to April 9, 2015. (This court has previously agreed, on two occasions, to extend Ms. Corn's turn in date from January 8, 2015, to March 5, 2015.)
As the court is aware, on January 11, 2015, Ms. Corn's 16 year old niece, Kassidy Clark, was killed in a car crash (along with two other teenagers - see, http://www.komonews.com/news/local/3-teens-die-in-overnight-rollover-crash-near-Seabeck-288194801.html). Because of the resulting criminal investigation and the fact that the funerals needed to be held on different days so friends and loved ones can attend all three, there has been some delay in scheduling the private, family only service, for Ms. Clark.
Presently, the family is hoping to have the private, ash scattering "service", as near to March 26, 2015 as possible. The reason(s) for the delay necessitating this request are twofold: (1) Ms. Clark's birthday would have been March 26, 2015 and the family believes having the ceremony as near as possible to what would have been her birthday seems sadly appropriate; and, (2) Ms. Clark's brother, Kameron Clark, is in the Army reserve and is at "boot camp" in Virginia. He will not be back in Washington (state) until approximately March 20, 2015. Obviously, it is the hope of the family to have everyone (the family) present for the farewell to Ms. Clark.
Scheduling these "events" has been an ongoing, open wound for the family. As such, the "scheduling" has been somewhat fluid. On behalf of Ms. Corn (and her family), I apologize to the court (and staff) for any additional work this request (and the previous requests) has caused.
Therefore, it is respectfully requested this court modify Ms. Corn's turn in date from March 5, 2015, to April 9, 2015.
Counsel for the government, Lee S. Bickley, has been notified of this request and has no objection.
ORDER
IT IS FOUND AND ORDERED.