Opinion
Case No. CR 07-515-03 WBS
07-25-2012
UNITED STATES OF AMERICA, Plaintiff, v. ALEX HERNANDEZ, Defendant.
BENJAMIN B. WAGNER United States Attorney MICHAEL M. BECKWITH Assistant U.S. Attorney Attorneys for Plaintiff DAVID J. COHEN Attorneys for Defendant ALEX HERNANDEZ
DAVID J. COHEN, ESQ.
California Bar No. 145748
BAY AREA CRIMINAL LAWYERS, PC
Attorneys for Defendant Alex Hernandez
STIPULATION TO CONTINUE SELF-
SURRENDER DATE OF MR. HERNANDEZ
AND [PROPOSED] ORDER THEREON
IT IS HEREBY STIPULATED by and between the parties that the surrender date for Alex Hernandez, currently set for July 26, 2012, be extended by 10 days to August 6, 2012.
The reason for this stipulation is that Mr. Hernandez was shot four times on July 21, 2012 and has sustained severe injuries. He was admitted to the ICU at Mercy San Juan Hospital in the early morning of July 22, 2012. Mr. Hernandez remains in the ICU.
The parties agree that, under the circumstances, a continuance of the surrender date of July 26, 2012 to August 6, 2012, or a period of 10 days is appropriate. Within that 10 day period, the parties intend to ascertain Mr. Hernandez' prognosis, and when and to where (a Bureau of Prisons hospital facility or a Bureau of Prisons prison camp as is currently contemplated) it would be appropriate for him to surrender.
IT IS SO STIPULATED.
BENJAMIN B. WAGNER
United States Attorney
By: _________________
MICHAEL M. BECKWITH
Assistant U.S. Attorney
Attorneys for Plaintiff
By: _________________
DAVID J. COHEN
Attorneys for Defendant
ALEX HERNANDEZ
IT IS SO ORDERED.
_________________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE