Opinion
CASE NO: 2:10-CR-0255
09-20-2011
UNITED STATES OF AMERICA, Plaintiff, v. FRENCH GULCH NEVADA MINING CORPORATION, BULLION RIVER GOLD CORPORATION, PETER MARTIN KUHN, and KIEDOCK KIM, Defendants.
MALCOLM S. SEGAL - 075481 JAMES P. MAYO - 169897 SEGAL & KIRBY LLP Attorneys for Defendant KIEDOCK KIM
MALCOLM S. SEGAL - 075481
JAMES P. MAYO - 169897
SEGAL & KIRBY LLP
Attorneys for Defendant
KIEDOCK KIM
STIPULATION AND PROPOSED
ORDER MODIFYING TERMS OF
PRETRIAL RELEASE TO PERMIT
SHORT-TERM TRAVEL TO AND
FROM CANADA AND FOR RELEASE
OF DEFENDANT'S PASSPORT
The defendant, KIEDOCK KIM, through his counsel of record, and plaintiff United States of America, through its counsel, Assistant United States Attorney Samuel Wong, agree and stipulate that the condition of pre-trial release restricting the defendant's travel to the Eastern and Northern Districts of California shall be modified as follows: The defendant shall be permitted to travel to and from Vancouver, British Columbia, Canada, for a seven-day period commencing on September 22, 2011, and returning on September 29, 2011, for the memorial services and funeral for his father, who passed away in Vancouver on Saturday evening, September 17, 2011.
The parties further agree and stipulate that the condition of pre-trial release requiring the defendant to surrender his passport to the Clerk of the Court may be modified to permit the Clerk to release the previously-surrendered passport to counsel for the defendant so that the defendant may travel to Canada for the memorial service and funeral of his father. Upon return to the United States, the defendant shall surrender his passport to the Clerk of the Court.
Dated: September _____ , 2011
Respectfully submitted,
SEGAL & KIRBY LLP
MALCOLM SEGAL
Attorneys for Defendant
KIEDOCK KIM
SAMUEL WONG
Assistant United States Attorney
(By permission)
ORDER
GOOD CAUSE APPEARING, and pursuant to the stipulation of the parties, the condition of pre-trial release restricting the defendant's travel to the Eastern and Northern Districts of California is modified as follows: The defendant is permitted to travel to and from Vancouver, British Columbia, Canada, for a seven-day period commencing on September 22, 2011, and returning on September 29, 2011 for the memorial services and funeral for his father.
The condition of pre-trial release requiring the defendant to surrender his passport to the Clerk of the Court is hereby modified and the Clerk shall release the previously-surrendered passport to counsel for the defendant. Upon return to the United States, the defendant shall surrender his passport to the Clerk of the Court. IT IS SO ORDERED.
GARLAND E. BURRELL, JR.
United States District Judge