Filed: Jun. 12, 2019
Latest Update: Jun. 12, 2019
Summary: STIPULATION AND [ PROPOSED ] ORDER TO EXTEND PERIOD TO FILE SECURED BOND EDMUND F. BRENNAN , Magistrate Judge . Plaintiff United States of America, by and through its counsel of record, and the Defendant, by and through her counsel of record, hereby stipulate as follows: 1. On May 30, 2019 Defendant Johnesha Thompson was released on a $200, 000 bond by Magistrate Judge Debra Barnes. That bond was signed by Defendant's grandmother Dorothea Adair. The bond was unsecured as of May 30, 201
Summary: STIPULATION AND [ PROPOSED ] ORDER TO EXTEND PERIOD TO FILE SECURED BOND EDMUND F. BRENNAN , Magistrate Judge . Plaintiff United States of America, by and through its counsel of record, and the Defendant, by and through her counsel of record, hereby stipulate as follows: 1. On May 30, 2019 Defendant Johnesha Thompson was released on a $200, 000 bond by Magistrate Judge Debra Barnes. That bond was signed by Defendant's grandmother Dorothea Adair. The bond was unsecured as of May 30, 2019..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND PERIOD TO FILE SECURED BOND
EDMUND F. BRENNAN, Magistrate Judge.
Plaintiff United States of America, by and through its counsel of record, and the Defendant, by and through her counsel of record, hereby stipulate as follows:
1. On May 30, 2019 Defendant Johnesha Thompson was released on a $200, 000 bond by Magistrate Judge Debra Barnes. That bond was signed by Defendant's grandmother Dorothea Adair. The bond was unsecured as of May 30, 2019. The Court ordered that a $200,000 secured bond be filed within two weeks (June 13, 2019) secured by property owned by Ms. Adair. The Court also indicated that if more time was needed to get a secured bond in place Defendant could apply to the Court for an extension.
Attorney Hedberg has diligently pursued the bond. However, there has been a delay in getting title search documents.
As a result, Defendant does not feel that the proper material will be ready so that the bond can be posted by June 13, 2019.
Defendant has spoken with AUSA David Spencer and PTSOs Margareta Zepeda and Daryl Walker and informed them of the situation.
Both have agreed that an extension is appropriate.
2. The parties agree and stipulate, and request that the Court find the following:
a. Defense counsel has diligently pursued a secured bond in this case.
b. A delay has occurred in the acquisition of a title report by Defense Counsel;
c. It is appropriate to extend the time period to file the secured bond package to June 26, 2019;
d. The government does not object to the continuance.
IT IS SO STIPULATED
Respectfully submitted
/s/ Olaf W. Hedberg /s/ David Spencer
Olaf W. Hedberg David Spencer
Attorney for Johnesha Thompson Assistant United States Attorney
ORDER
GOOD CAUSE APPEARING, it is hereby ordered that the June 13, 2019 deadline to post a secured bond in the matter at bar be extended to June 26, 2019.
IT IS SO ORDERED.
