Free Stipulation - District Court of California - California

Case 3:07-mj-70721-MAG

Document 42

Filed 01/24/2008

Page 1 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

EDWIN K. PRATHER (State Bar No. 190536) CLARENCE & DYER LLP 899 Ellis Street San Francisco, California 94109 Telephone: 415.749.1800 Facsimile: 415.749.1694 Email: [email protected] Attorneys for Defendant Nancy Summersgill

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, Plaintiff, v. NANCY SUMMERSGILL, Defendants. Case No.: CR 3-07-70721 MEJ STIPULATION AND [PROPOSED] ORDER FOR MODIFICATION TO A TERM AND CONDITION OF DEFENDANT NANCY SUMMERSGILL'S PRETRIAL RELEASE

Defendant Nancy Summersgill was released by this Court on December 11, 2007, and ordered to appear in the Eastern District of Virginia for case no. 1:08CR0008GBL. On January 14, 2008, Ms. Summersgill in fact appeared in the Eastern District of Virginia and entered a guilty plea as to that matter. She is scheduled to return for sentencing on April 25, 2008. Ms. Summersgill's conditions of release restrict her movement to the Northern District of California, the Eastern District of Virginia and the state of Hawaii. Defendant Summersgill requests that this condition be modified so that she may also travel to the District of Columbia with the approval of Pretrial Services. Ms. Betty Kim, defendant Summersgill's Pretrial Services Officer, has indicated her consent to the Court's modification of this term of defendant Summersgill's pretrial release. ///
Page 1 Stipulation and [Proposed] Order For Modification to a Term and Condition of Defendant Nancy Summersgill's Pretrial Release [Case No.: CR 3-07-70721 MEJ]

Case 3:07-mj-70721-MAG

Document 42

Filed 01/24/2008

Page 2 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Similarly, the prosecutor in defendant Summersgill's matter in the Eastern District of Virginia, Assistant United States Attorney Dennis M. Fitzpatrick consents to the Court's modification of this term of defendant Summersgill's pretrial release. IT IS SO ORDERED. Dated: January ____, 2008 _______________________________________ MARIA ELENA JAMES UNITED STATES MAGISTRATE JUDGE Approved as to form: __/s/ _________ EDWIN K. PRATHER Clarence & Dyer LLP Attorneys for Defendant Nancy Summersgill

_/s/ _________ DENNIS M. FITZPATRICK Assistant United States Attorney

Page 2 Stipulation and [Proposed] Order For Modification to a Term and Condition of Defendant Nancy Summersgill's Pretrial Release [Case No.: CR 3-07-70721 MEJ]

Case 3:07-mj-70721-MAG

Document 42

Filed 01/24/2008

Page 3 of 3

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Proof of Service I, Abbie Chin, declare as follows: I am over eighteen years of age and not a party to the within action; my business address is 899 Ellis Street, San Francisco, California 94109; I am employed in the County of San Francisco. On January 24, 2008, I served a copy, with all exhibits, of the following documents: · STIPULATION AND [PROPOSED] ORDER FOR MODIFICATION TO A TERM

AND CONDITION OF DEFENDANT NANCY SUMMERSGILL'S PRETRIAL RELEASE ___X___ (BY FAX) By transmitting by facsimile machine to the number addressed as below; the facsimile machine I used complied with California Rules of Court, rule 2003 and no error was reported by the machine. Pursuant to California Rules of Court, rule 2006(d), I caused the machine to print a transmission record of the transmission. ____X__ (BY ELECTRONIC SERVICE) I caused an electronic delivery subject to 28 U.S.C ¶1746, Local Rules or General Orders of this Court regarding Electronic Case Filing. All pleadings and papers must be electronically served in accordance with those Rules or General Orders with email address(es) as noted below: By Email Dennis Fitzpatrick United States Attorney's Office 2100 Jamieson Ave Alexandria, VA 22314 Email: [email protected] By Fax: Pretrial Services, San Francisco Office Betty Kim 450 Golden Gate Avenue, Rm. 5497 San Francisco, CA 94102 Fax: (415) 436-7517 I declare under penalty of perjury under the laws of the state of California that the foregoing is true and correct and that this declaration was executed on the above stated date.

/s/: Abbie Chin Abbie Chin

Page 3 Stipulation and [Proposed] Order For Modification to a Term and Condition of Defendant Nancy Summersgill's Pretrial Release [Case No.: CR 3-07-70721 MEJ]