Opinion
No. CR-S-11-CR-296 WBS
04-16-2013
UNITED STATES OF AMERICA, Plaintiff, v. MANUEL HERRERA, Defendant.
JOHN R. MANNING Attorney for Defendant Manuel Herrera LEE BICKLEY Assistant United States Attorney
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
1111 H Street, # 204
Sacramento, CA. 95814
(916) 444-3994
Fax (916) 447-0931
Attorney for Defendant
MANUEL HERRERA
STIPULATION AND PROPOSED ORDER
ALLOWING MANUEL HERRERA TO
EXTEND HIS TRIP TO MEXICO
IT IS HEREBY STIPULATED AND AGREED between defendant Manuel Herrera, by and through his undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Lee Bickley, Mr. Herrera may, extend his present trip to Mexico until April 18, 2013. The Court previously signed a stipulation allowing Mr. Herrera to travel to Mexico between April 5, 2013 and April 15, 2013, to visit his ailing mother. (Mr. Herrera's mother is recuperating from a cardiac incident.) Mr. Herrera's mother is scheduled for a follow up exam on April 17, 2013. Mr. Herrera would like to accompany his mother and be present for this follow up visit. It is stipulated Mr. Herrera must return to the United States by April 18, 2013 and must check in with, and surrender his passport to, his Pre-Trial Services Officer within 24 hours of returning to the United States, but in any event, no later than April 19, 2013. (Pretrial Services will defer to the Court on this matter.) IT IS SO STIPULATED.
____________
JOHN R. MANNING
Attorney for Defendant
Manuel Herrera
____________
LEE BICKLEY
Assistant United States Attorney
IT IS SO ORDERED,
____________
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE