Opinion
No. CR 11-00143-DLJ
11-23-2011
UNITED STATES OF AMERICA, Plaintiff, v. JUVINNA WINSKOWSKI, Defendants.
BARRY J. PORTMAN VARELL L. FULLER Assistant Federal Public Defender Counsel for Defendant WINSKOWSKI
BARRY J. PORTMAN
VARELL L. FULLER
Assistant Federal Public Defender
Counsel for Defendant WINSKOWSKI
STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING DATE ON DEFENSE MOTION FOR RECONSIDERATION OF BOND
Hon. Howard. R. Lloyd
STIPULATION
The parties, by and through their respective counsel, hereby stipulate and jointly request that the hearing date currently set in this matter for Thursday December 1, 2011, at 1:30 p.m., be continued to Wednesday, December 14, 2011, at 1:30 p.m.
Counsel for Ms. Winskowski previously requested this matter be placed on calendar on December 1, 2011, for a hearing on a defense motion to reopen the detention hearing based on changed circumstances, and set conditions releasing the defendant to a residential drug treatment facility. Defense counsel requires additional time to prepare and submit arguments in support of the defense motion for reconsideration of bond, and therefore respectfully request a continuance of the hearing date to December 14, 2011, at 1:30 p.m.
Accordingly, the parties therefore respectfully request that the Court continue the hearing date previously set on December 1, 2011, at 1:30 a.m. to December 14, 2011, at 1:30 p.m.
VARELL L. FULLER
Assistant Federal Public Defender
ALLISON MARSTON DANNER
Assistant United States Attorney
[PROPOSED] ORDER
Good cause appearing and by stipulation of the parties, it is hereby ORDERED that the hearing on the defense motion for reconsideration of bond previously set for Thursday, December 1, 2011, is continued to Wednesday, December 14, 2011, at 1:30 p.m.
IT IS SO ORDERED.
THE HON. HOWARD R. LLOYD
United States Magistrate Judge