Opinion
Case No: 2:07-CR-570 FCD
10-07-2011
UNITED STATES OF AMERICA, Plaintiff, v. CONN, et al, Defendants.
William E. Bonham, SB# 55478 Attorney at Law Hotel de France Bldg., Old Sacramento Attorney for defendant John CONN
William E. Bonham, SB# 55478
Attorney at Law
Hotel de France Bldg., Old Sacramento
Attorney for defendant John CONN
STIPULATION AND ORDER
ORDER TO EXTEND SELF
SURRENDER DATE
The defendant, John Conn, by and through his undersigned counsel, and the United States through its undersigned counsel, agree and request that the self-surrender date currently set for Monday, October 31, 2011 by 2:00 pm be extended to Monday, December 5, 2011 by 2:00 pm.
An extension is requested to provide Mr. Conn with sufficient time to complete two jobs that will add to his family's savings prior to his incarceration.
At his sentencing on September 19, 2011 Mr. Conn was sentenced on count 1 to 28 months imprisonment. He was ordered to self-surrender by 2:00 pm on Monday, October 31, 2011 to the designated institution or the U.S. Marshalls.
Mr. Conn works in construction and is currently employed by Franke Mulrine in Leggett, CA on a remodeling job that is expected to be completed, in approximately 3 more weeks.
Following the completion of his current job Mr. Conn has been offered an opportunity for employment by Christine Carson in Whitehorn, CA to complete a new addition to her residence, which he began before suspending work to take the Mulrine project. This job is expected to be completed, in approximately 3 weeks.
As the completion dates are approximate a self-surrender date of Monday, December 5, 2011 should be sufficient to complete each project as well as account for any unforeseen issues related to the work that may arise.
As a result of his incarceration Mr. Conn's family's income will substantially decrease. In preparation they have been saving and would benefit if Mr. Conn was able to complete the aforementioned jobs and receive payment.
I have spoken with PTS Officer Taifa Gaskins and she does not oppose an extension of Mr. Conn's self surrender date. It should also be noted that Mr. Conn has been in complete compliance with Pretrial Services and the conditions of his release.
I, William E. Bonham, the filing party have received authorization from AUSA Heiko Coppola to sign and submit this stipulation and proposed order on his behalf.
Accordingly, the defense and the United States agree and stipulate that Mr. Conn should self- surrender to the designated institution or the USM by 2:00 pm on Monday, December 5, 2011.
BENJAMIN B. WAGNER
United States Attorney
HEIKO COPPOLA
Assistant U.S. Attorney
WILLIAM E. BONHAM
Counsel for defendant Conn
ORDER
IT IS SO ORDERED. The self-surrender date for defendant John Conn to surrender to the designated facility or USM, currently set for Monday, October 31, 2011 by 2:00 pm is extended to Monday, December 5, 2011 by 2:00pm.
FRANK C. DAMRELL, JR.
UNITED STATES DISTRICT JUDGE