Opinion
TONI H. WHITE, ATTORNEY AT LAW, Auburn, CA, Attorney for Defendant, HEBER VASQUEZ.
REQUEST AND ORDER
JOHN A. MENDEZ, District Judge.
Defendant, HEBER VASQUEZ, by and through his counsel of record, TONI WHITE submits this request and proposed order in support of his request for a day pass to attend his grandmother's funeral services. The Court indicated at the time of Mr. Vasquez' sentencing on February 24, 2015 that Mr. Vasquez may submit a proposed order requesting the day pass if he were not released from the Sacramento County jail prior to the funeral. Mr. Vasquez is still in custody and, as such, requests a day pass to allow his attendance at the funeral.
Defense counsel has been in contact with Mr. Vasquez' family, the U.S. Marshall's Office and defense counsel's private investigator and submits the following information and proposed plan, in support of Mr. Vasquez' request for a day pass:
1. The defense has contact licensed private investigator Victor Sanchez to take custody of Mr. Vasquez and transport him to and from the funeral services. In addition to being a licensed private investigator, Mr. Sanchez is a retired Sacramento Police officer. Investigator Sanchez' cell phone number is (916) 425-6112. His email address is vuspi2@gmail.com.
2. The Marshall's Office will have Mr. Vasquez present at the lockup facility located at 501 I Street no later than 10:00 a.m. on Friday, February 27th for release to Investigator Sanchez.
3. Mr. Vasquez' family will meet Investigator Sanchez and the Marshalls at the above-mentioned lockup facility with appropriate clothing.
4. The funeral home is Evergreen Memorial located at 3030 Fruitridge Road, Sacramento CA 95820. Their phone number is XXX-XXX-XXXX. A letter from them confirming the date of the funeral service as February 27, 2015 is attached as Exhibit 1.
5. The program for the funeral services is attached as Exhibit 2 and confirms that the service is from 11:00 a.m. until 12:30 p.m. at the Iglesia Apostolica Monte Zion Church located at 6446 Lange Avenue, Sacramento CA 95823.
6. The burial will start at approximately 1:00 and will last possibly an hour and a half. There is luncheon afterwards at which there will be no alcohol.
7. For the Court and Marshall's information, the family member providing this information is Rebecca Vasquez and her email is vasquezrebecca17@yahoo.com. Mr. Vasquez' father, Cesar Vasquez, will be meeting the Marshalls prior to Mr. Vasquez pickup time to deliver the clothing. Cesar Vasquez' phone number is XXX-XXX-XXXX.
8. Investigator Sanchez would return Mr. Vasquez to the Marshall's lockup no later than 3:30 p.m.
9. Defense counsel spoke with the Marshall's Office and the pick-up time of 10:00 a.m. and the return time of 3:30 p.m. is acceptable to them.
10. It is requested that Mr. Vasquez be released to Investigator Sanchez no later than 10:00 a.m. from the U.S. Marshall's lockup on February 27, 2015. It is requested that he be allowed to be escorted by Investigator Sanchez directly to the funeral and related above-mentioned activities, to participate in the activities and that he be ordered to be returned by Investigator Sanchez to the U.S. Marshall's lockup no later than 3:30 p.m. on February 27, 2015 for transport back to the Sacramento Main Jail.
ORDER
IT IS SO ORDERED.