Opinion
No. 2:10-MJ-00360 DAD
01-12-2012
DANIEL J. BRODERICK Federal Defender Linda Harter LINDA HARTER Chief Assistant Federal Defender Attorney for Defendant ILDEFONSO JIMENEZ BENJAMIN B. WAGNER United States Attorney David Petersen DAVID PETERSEN Special AUSA
DANIEL J. BRODERICK, #89424
Federal Defender
LINDA C. HARTER, CA Bar #179741
Chief Assistant Federal Defender
Designated Counsel for Service
SAGE KAVENY
Certified Student Attorney
Attorney for Defendant
ILDEFONSO JIMENEZ
STIPULATION & ORDER FOR EXTENSION OF TIME TO SELF SURRENDER
Defendant, ILDEFONSO JIMENEZ, through counsel, hereby requests a two-week extension of his self-surrender date from January 13, 2012 to January 27, 2012, at 2:00 p.m. Mr. Jimenez is sentenced to three days in jail.
Mr. Jimenez seeks an extension of time to self-surrender because defense counsel was not notified of his designation until January 10, 2012. This is not sufficient time for Mr. Jimenez to make arrangements for his self-surrender. Mr. Jimenez lives in Modesto, CA, where he works as a landscaper, and is scheduled to leave town on January 12, 2012 to travel to Corcoran, CA for work. In the interest of keeping his job, Mr. Jimenez respectfully requests this extension to allow him to give timely notice to his employer. Furthermore, Mr. Jimenez does not drive and must arrange for transportation to his designated facility in Elk Grove, CA.
Special Assistant United States Attorney David Petersen stipulates to the Court extending the self-surrender date to January 27, 2012. Mr. Jimenez requests that this Court vacate the self-surrender date of January 13, 2012, and enter an Order extending the self-surrender date two weeks to January 27, 2012.
Respectfully submitted,
DANIEL J. BRODERICK
Federal Defender
Linda Harter
LINDA HARTER
Chief Assistant Federal Defender
Attorney for Defendant
ILDEFONSO JIMENEZ
BENJAMIN B. WAGNER
United States Attorney
David Petersen
DAVID PETERSEN
Special AUSA
The self-surrender date of January 13, 2012 is vacated. Defendant, Ildefonso Jimenez, shall surrender to the facility designated by the Bureau of Prisons or to the United States Marshal Service on January 27, 2012 by 2:00 p.m. IT IS SO ORDERED.
____________________________
DALE A. DROZD
UNITED STATES MAGISTRATE JUDGE