Opinion
Case No.: Cr.S-08-471-GEB.
July 6, 2010
LAW OFFICES OF JOHNNY L. GRIFFIN III, JOHNNY L. GRIFFIN III (SBN 118694), SACRAMENTO, CA.
Mark J. Reichel, Attorney for Defendant, Daljit Sekhon.
Based on the unavailability of Attorney Mark Reichel, and the urgency in obtaining the passport, Attorney Johnny L. Griffin, III was requested and authorized to electronically file this Proposed Order on Defendant's behalf.
Defendant, by and through her undersigned counsel, hereby move the court for an order authorizing her to travel outside the Eastern District of California, and for the Clerk of the United States District Court for the Eastern District of California to release her passport for this travel.
Specifically, Defendant requests to travel to Vancouver, Canada leaving on July 7, 2010 and returning on July 11, 2010. The purpose of this travel is to attend a wedding. Defendant will need her passport, which was previously surrendered to the Clerk of the United States District Court for the Eastern District of California, for this travel. Defendant's Passport Number is 159234165. Defendant will surrender her passport back to the Clerk's Office no later than July 13, 2010. The Government has been advised of these requests and has no objection.
It should be noted that though Defendant is on pretrial release, she is not being supervised by Pretrial Services. Therefore, authorization was not sought from Pretrial Services.
Respectfully submitted,
The United States of America, by and through its undersigned attorney, Assistant United States Attorney Robert Tice-Raskin, has no objection to Defendant's request for travel to Vancouver, Canada leaving on July 7, 2010 and returning on July 11, 2010. Further, the United States does not object to the release of her passport for this travel with the condition that it be surrendered back to the Clerk's Office no later than close of business on July 13, 2010.
Assistant U.S. Attorney Robert Tice-Raskin has telephonically authorized Johnny L. Griffin, III to electronically sign this [Proposed] Order on his behalf.