Opinion
Case No. 2:12-CR-00328-WBS
02-26-2013
Assistant United States Attorney TODD PICKLES BARTH TOZER & DALY LLP KRESTA NORA DALY Attorneys for Defendant ROBIN DIMICELI
Kresta Nora Daly, SBN 199689
Thomas W. Barth, SBN 154075
BARTH TOZER & DALY LLP
431 "I" Street, Suite 201
Sacramento, California 95814
Telephone: (916) 440-8600
Facsimile: (916) 440-9610
Email: kdaly@btdlegal.com
Attorneys for Defendant
ROBIN DIMICELI
STIPULATION AND ORDER
MODIFYING PRETRIAL RELEASE
CONDITIONS
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant Robin Dimiceli, by and through her counsel of record, Kresta Nora Daly, hereby stipulate as follows:
1. On September 28, 2012 Robin Dimiceli was arraigned and released on a $50,000 unsecured bond. The appearance bond was co-signed by her then husband, Allen Atencio.
2. In December 2012 Robin Dimiceli located suspected contraband on one or more of the family's computers. She reported the incident to the police. She moved out of the home she shared with her husband and returned to Copperopolis. Ms. Dimiceli is in the process of divorcing Mr. Atencio.
3. Pre-Trial Services Officer Ryan Garcia was informed of these events in a timely manner. The parties and Pre-Trial Services agree in light of these events it is no longer appropriate for Mr. Atencio to be the co-signer on the unsecured bond. The parties hereby stipulate Guy and Johanna Grenny, Robin Dimiceli's parents, shall execute a new unsecured appearance bond in the amount of $50,000.
4. Pre-Trial Services Officer Ryan Garcia contacted Mr. and Mrs. Grenny. Mr. Garcia is satisfied that Mr. and Mrs. Grenny are appropriate co-signers on a new $50,000 unsecured bond.
5. The parties agree and stipulate, and request that the Court find the following:
(a) The unsecured appearance bond dated September 28, 2012 be exonerated.
(b) That Robin Dimiceli be given until February 1, 2013 to file a new unsecured appearance bond, co-signed by Guy and Johanna Grenny.
It is so stipulated.
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Assistant United States Attorney TODD PICKLES
BARTH TOZER & DALY LLP
By ___________
KRESTA NORA DALY
Attorneys for Defendant ROBIN DIMICELI
ORDER
IT IS SO ORDERED.
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DALE A. DROZD
UNITED STATES MAGISTRATE JUDGE