STIPULATION AND [PROPOSED] ORDER TO EXTEND SURRENDER DATE

JON S. TIGAR, District Judge.

When defendant Joel Dominguez was sentenced on October 26, 2018, the Court set a surrender date of January 4, 2019 for Mr. Dominguez to serve his four year sentence with the Bureau of Prisons. The parties hereby stipulate and agree that the surrender date for Mr. Dominguez can be extended BY ONE MONTH to February 4, 2019.

The reason for the requested extension of the surrender date for Mr. Dominguez is so that counsel for Mr. Dominguez, Robert Waggener, can research and address the Bureau of Prisons designation for Mr. Dominguez which was received on December 31, 2018. By an email on December 31, 2018 to Mr. Waggener, Pearline Jackson, Administrative Support Assistant for the United States Marshals Service attached the designation for Mr. Dominguez, asking that Mr. Dominguez be notified of the date and location where he had been designated. The attached designation for Mr. Dominguez was that he surrender on January 4, 2019 at McKean SCP, a Satellite Camp Prison somewhere in Pennsylvania.

When the Court sentenced Mr. Dominguez it recommended to the Bureau of Prisons "that the defendant be housed in a facility as close to the San Francisco Bay Area as possible, in order to facilitate family visitation." (Dkt. No. 60, page 2) With this newly received designation, Mr. Dominguez is being asked to surrender in four days over three thousand miles away from his family. It is fully recognized that the Court can only make housing recommendation to the Bureau of Prisons. However, an extension of the surrender date is being requested here by defense counsel in order to investigate an alternative designation, and in order to have a dialogue with representatives of the Bureau of Prisons and/or the United States Marshals Service about housing Mr. Dominguez closer to his family and young son. Assistant United States Attorney Sailaja M. Paidipaty and United States Probation Officer Brian Casai have no objection to an extension of the surrender date for Mr. Dominguez.

SO STIPULATED

[PROPOSED] ORDER

For the reasons stated above, the Court ORDERS that the surrender date for defendant Dominguez is extended from January 4, 2019, such that defendant shall now surrender for service of sentence at the institution designated by the Bureau of Prisons by 12:00 p.m. on February 4, 2019.