Filed: Nov. 01, 2012
Latest Update: Nov. 01, 2012
Summary: MOTION TO STAY SURRENDER DATE LLOYD D. GEORGE, District Judge. COMES NOW, the Defendant, DANNY AHN, by and through his counsel, WILLIAM B. TERRY, ESQ., of the law offices of WILLIAM B. TERRY, CHARTERED, and moves this Honorable Court to stay the surrender date for a minimum of seven weeks due to medical reasons in the instant case. This Motion is made and based on the attached analysis of facts in support hereof, and any oral arguments as maybe presented at the hearing in this matter. ANALY
Summary: MOTION TO STAY SURRENDER DATE LLOYD D. GEORGE, District Judge. COMES NOW, the Defendant, DANNY AHN, by and through his counsel, WILLIAM B. TERRY, ESQ., of the law offices of WILLIAM B. TERRY, CHARTERED, and moves this Honorable Court to stay the surrender date for a minimum of seven weeks due to medical reasons in the instant case. This Motion is made and based on the attached analysis of facts in support hereof, and any oral arguments as maybe presented at the hearing in this matter. ANALYS..
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MOTION TO STAY SURRENDER DATE
LLOYD D. GEORGE, District Judge.
COMES NOW, the Defendant, DANNY AHN, by and through his counsel, WILLIAM B. TERRY, ESQ., of the law offices of WILLIAM B. TERRY, CHARTERED, and moves this Honorable Court to stay the surrender date for a minimum of seven weeks due to medical reasons in the instant case.
This Motion is made and based on the attached analysis of facts in support hereof, and any oral arguments as maybe presented at the hearing in this matter.
ANALYSIS OF FACTS
The defendant, Danny Ahn, is scheduled to surrender himself on November 26, 2012 in the instant case. The Defendant is further currently scheduled to have back surgery on November 5, 2012. Attached hereto as Exhibit "A" for the Court's review is a copy of the Pre-operative History and Physical Examination and supporting report from Dr. Andrew Cash with Desert Institute of Spine Care. As the documentation indicates, the Defendant will need six weeks before physical therapy for healing followed by six weeks of physical therapy for reconditioning. Therefore it is respectfully requested that the surrender date be stayed for a minimum of seven weeks.
Exhibit "A"
