U.S. v. MONTGOMERY, CR 13-0028 CW. (2013)
Court: District Court, N.D. California
Number: infdco20130730a13
Visitors: 17
Filed: Apr. 12, 2013
Latest Update: Apr. 12, 2013
Summary: AGREEMENT AND STIPULATION OF THE PARTIES TO AMEND RICHARD MILLER'S RELEASE CONDITIONS TO ALLOW HIM TO TRAVEL TO LOS ANGELES FOR BUSINESS KANDIS A. WESTMORE, Magistrate Judge. I, Darryl A. Stallworth, declare as follows: 1. That I am the attorney for Defendant Richard Miller in this action. 2. That Mr. Miller is employed by US Pacific Investments LLC. 3. That Mr. Miller's employment requires him to meet and consult with the company's Southern California branch offices. 4. That Mr. Miller's
Summary: AGREEMENT AND STIPULATION OF THE PARTIES TO AMEND RICHARD MILLER'S RELEASE CONDITIONS TO ALLOW HIM TO TRAVEL TO LOS ANGELES FOR BUSINESS KANDIS A. WESTMORE, Magistrate Judge. I, Darryl A. Stallworth, declare as follows: 1. That I am the attorney for Defendant Richard Miller in this action. 2. That Mr. Miller is employed by US Pacific Investments LLC. 3. That Mr. Miller's employment requires him to meet and consult with the company's Southern California branch offices. 4. That Mr. Miller's e..
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AGREEMENT AND STIPULATION OF THE PARTIES TO AMEND RICHARD MILLER'S RELEASE CONDITIONS TO ALLOW HIM TO TRAVEL TO LOS ANGELES FOR BUSINESS
KANDIS A. WESTMORE, Magistrate Judge.
I, Darryl A. Stallworth, declare as follows:
1. That I am the attorney for Defendant Richard Miller in this action.
2. That Mr. Miller is employed by US Pacific Investments LLC.
3. That Mr. Miller's employment requires him to meet and consult with the company's Southern California branch offices.
4. That Mr. Miller's employer requires his presence this weekend in Newport Beach to finalize a contract.
5. That Mr. Miller's next Court date is June 10, 2013.
6. The following is Mr. Miller's itinerary for the weekend:
04/12 10:00 am-6:00pm driving to Orange County
04/12 7:00 pm-Dinner meeting Newport Beach Marriot
04/13 9:00 am-Breakfast meeting
04/13 12:00-6:00pm-Leisure time
04/13 7:00pm-Dinner meeting
04/14 9:00 am-Breakfast meeting
04/14 12:00-4:00 pm-Final Contract Overview
04/14 7:00 pm-Leisure Dinner
04/15 9:00am-Return to Bay Area
7. That Mr. Miller has lived and worked in California his entire life.
8. That Mr. Miller has never missed a court date and has abided by all of his release conditions.
9. Given the complex nature of this case and the numerous codefendants it may be some time before a resolution can be reached.
10. That Mr. Miller needs to stay employed during this period of time, which will require him to occasionally travel to Southern California.
11. That Assistant United States Attorney Kevin Barry is agreeable to Mr. Miller traveling to Newport Beach for Business this weekend. On Wednesday April 10, 2013 Mr. Barry left me a voicemail stating I could sign this stipulation on his behalf.
12. Pre-Trial Services Officers Taifa Gaskins and Denise Mancia are also agreeable to Mr. Miller traveling to Newport Beach for Business this weekend. On Thursday April 11, 2013 Ms. Mancia informed me that she had signed this stipulation and faxed it to my office. Unfortunately the fax had an error and only sent three blank pages. (See Attached). Ms. Mancia is out of the office today and will be unable to send another fax.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed this 12th day of April, 2013 at Oakland, California.
I KEVIN J. BARRY STIPULATE THAT RICHARD MILLER BE ALLOWED TO TRAVEL TO NEWPORT BEACH THIS WEEKEND AS OUTLINED ABOVE.
KEVIN J. BARRY
ASSISTANT UNITED STATES ATTORNEY
I TAIFIA GASKINS STIPULATE THAT RICHARD MILLER BE ALLOWED TO TRAVEL TO NEWPORT BEACH THIS WEEKEND AS OUTLINED ABOVE.
DENISE MANCIA
PRE-TRIAL SERVICES OFFICER
IT IS SO ORDERED on this, the 11th day of April 2013 that Defendant Richard Miller shall be allowed to travel to Newport Beach for Business as referenced in the above mentioned itinerary.
Source: Leagle
