Opinion
No.: CR 11-0830 EMC
11-28-2011
UNITED STATES OF AMERICA, Plaintiff, v. BARRY SOMERS, Defendant.
Nicole Giacinti (SBN 233121) Morris & Giacinti LLP Counsel for Defendant, Barry Somers
Nicole Giacinti (SBN 233121)
Morris & Giacinti LLP
Counsel for Defendant, Barry Somers
STIPULATION AND [PROPOSED]
ORDER AUTHORIZING DEFENDANT
TO SEARCH FOR EMPLOYMENT
1. On November 4, 2011, a detention hearing was held and the Court ordered Mr. Somers released from U.S. Marshall Custody. Mr. Somers was ordered to reside in a Halfway House and abide by the rules of the Halfway House.
2. Mr. Somers complied with that order and has been residing at the Geo Services Halfway House for nearly two weeks.
3. Currently, Mr. Somers is only authorized to leave the Halfway House for doctor's appointments, court hearings, and authorized legal appointments. Mr. Somers is not allowed to leave the Halfway House to job search.
4. Mr. Somers would like to be allowed to leave the Halfway House to look for work. Victoria Gibson, Mr. Somers's pre-trial service case manager, agrees that Mr. Somers should be permitted to leave the Halfway House to search for a job.
5. In light of the above, Mr. Somers respectfully requests that the Court order the Halfway House to allow Mr. Somers to leave the Halfway House to look for work, as approved by pre-trial services.
6. The government does not object to the request that Mr. Somers be permitted to leave the Halfway House to look for work, as approved by pre-trial services.
It is so stipulated.
Kevin Barry
Assistant United States Attorney
Nicole Giacinti
Counsel for Barry Somers
The Honorable Joseph C. Spero
United States Magistrate Judge
It is so ordered.