Opinion
09-CR-00543
01-19-2012
UNITED STATES OF AMERICA, Plaintiff, v. CHRISTINA NAVARRETTE, et al. Defendants.
ERIN J. RADEKIN Attorney at Law - SBN 214964 Attorney for Defendant CHRISTINA NAVARRETTE
ERIN J. RADEKIN
Attorney at Law - SBN 214964
Attorney for Defendant
CHRISTINA NAVARRETTE
STIPULATION FOR EXTENSION OF TIME
TO SELF-SURRENDER AND [PROPOSED] ORDER
STIPULATION
Defendant, CHRISTINA NAVARRETTE, by and through her attorney, Erin J. Radekin, hereby requests a three-week extension of her self-surrender date from January 23, 2012 to February 13, 2012.
The reason for this request is that, by order of the Court on December 30, 2011, the turn-in date of her co-defendant and partner, Jeffrey Abke, was modified to January 24, 2012, at 2:00 p.m. (see Docket No. 157), with the result that Mr. Abke's sentence will overlap with Ms. Navarrette's current sentence to begin on January 23, 2012. At sentencing the defendants requested that they serve different two-week periods of time so that one of them remained out of custody to care for Ms. Navarrette's children. The court complied with this request. It is thus necessary that Ms. Navarrette's turn-in date likewise be extended so that Mr. Abke has completed his sentence at the time Ms.
Navarrette turns herself in to serve her sentence and thus remains out-of-custody to care for the children. Assistant United States Attorney Jill Thomas stipulates to the Court extending the self-surrender date to February 13, 2012 and requests that this Court vacate the self-surrender date of January 23, 2012, and enter an Order extending the self-surrender date three weeks to February 13, 2012.
Accordingly, the parties respectfully request the Court adopt this proposed stipulation. IT IS SO STIPULATED
BENJAMIN WAGNER
United States Attorney
By: ____________
JILL THOMAS
Assistant United States Attorney
____________
ERIN J. RADEKIN
Attorney for Defendant
CHRISTINA NAVARRETTE
ORDER
For the reasons set forth in the accompanying stipulation and declaration of counsel, the self-surrender date of January 23, 2012 is VACATED. Defendant, CHRISTINA NAVARRETTE shall surrender to the facility designated by the Bureau of Prisons or to the United States Marshal Service by February 13, 2012 by 2:00 p.m.
IT IS SO ORDERED.
_____________________
EDMUND F. BRENNAN
UNITED STATES MAGISTRATE JUDGE