Opinion
Case No. 09-CR-0422 WBS
01-13-2012
UNITED STATES OF AMERICA, Plaintiff, v. THOMAS KEYS, et al. Defendant.
BENJAMIN WAGNER United States Attorney JEAN HOBLER Assistant United States Attorney ERIN J. RADEKIN Attorney for Defendant THOMAS KEYS
ERIN J. RADEKIN
Attorney at Law - SBN 214964
Attorney for Defendant
THOMAS KEYS
STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL APPEARANCE ON REVOCATION PROCEEDINGS
STIPULATION
Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Jean Hobler, and defendant, Thomas Keys, by and through his counsel, Erin J. Radekin, agree and stipulate to vacate the date set for initial appearance on probation revocation proceedings, January 17, 2012 at 9:30 a.m. and to continue such date to January 30, 2012 at 9:30 a.m. in the courtroom of the Honorable William B. Shubb.
The reason for this request is that Ms. Radekin sustained a fracture in her foot which required surgery on December 9, 2011, and she is on crutches until further determination of her doctor. She also has a medical appointment relating to such injury on January 17, 2012 that poses a conflict with the current date set for such proceeding. The court is advised that Ms. Hobler concurs with this request and has authorized Ms. Radekin to sign this stipulation on her behalf. The court is further advised that Ms. Radekin spoke with Mr. Keys' probation officer Garey White and he has no objection to this continuance and indicated that he will notify Mr. Keys' of the new date.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation. IT IS SO STIPULATED
BENJAMIN WAGNER
United States Attorney
By: ___________
JEAN HOBLER
Assistant United States Attorney
____________
ERIN J. RADEKIN
Attorney for Defendant
THOMAS KEYS
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the initial appearance on revocation proceedings date of January 17, 2012 at 9:30 a.m. is VACATED and the above-captioned matter is reset for initial appearance on revocation proceedings on January 30, 2012 at 9:30 a.m. IT IS SO ORDERED.
____________
WILLIAM B. SHUBB
UNITED STATES DISTRICT JUDGE