Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:07-cr—OO348—BZ Document 21 Filed 06/O2/2008 Page 1 of 3
1 Robert M. Amparan, SBN 172132 I
THE LAW OFFICES OF ROBERT M. AMPARAN
2 861 Bryant Street
San Francisco, CA 94103
3 Tel: (415) 431-1313
Fax: (415) 431-1312
4
Attorney for Defendant
5 ROBERT MINEMIER
6
7
8
UNITED STATES DISTRICT COURT
9
NORTHERN DISTRICT OF CALIFORNIA
10
11
UNITED STATES OF AMERICA,
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Plaintiff, CR 07—0348—0l—MAG
13 ·
v. REQUEST FOR WAIVER OF
14 DEFENDANT'S PERSONAL PRESENCE
ROBERT MINEMIER AT MISDEMEANOR SENTENCING
15
Defendant. I
16 / y
17 TO THE CLERK OF THE ABOVE ENTITLED COURT AND TO ASSISTANT UNITED
STATES ATTORNEY WENDY THOMAS:
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Defendant Robert Ralph Minemier, through counsel, hereby
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requests that this Court issue an Order waiving Mr. Minemier’s
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personal appearance at his misdemeanor sentencing on June 10,
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2008 at 10:30 a.m., and allowing him appear at said sentencing
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via telephone or video—conference from his home in Charlotte,
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North Carolina.
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Dated: June 2, 2008 .
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26 Signed: A
27 gsgRobert Amparangsg
Attorney for Defendant
28 Robert Minemier I
1 C

Case 3:07-cr—OO348—BZ Document 21 Filed 06/O2/2008 Page 2 of 3
1|Robert M. Amparan, SBN 172132 /
THE LAW OFFICES OF ROBERT M. AMPARAN
2 861 Bryant Street
San Francisco, CA 94103
3 Tel: (415) 431-1313
Fax: (415) 431-1312
4
Attorney for Defendant
5 ROBERT MINEMIER
6
V
8 UNITED STATES DISTRICT COURT
9 NORTHERN DISTRICT OF CALIFORNIA
10 I
11 UNITED STATES OF AMERICA, CR 07—0348—0I—MAG
12 Plaintiff, DECLARATION OF COUNSEL IN
SUPPORT OF REQUEST FOR WAIVER
13 v. OF DEFENDANT'S PERSONAL
PRESENCE AT MISDEMEANOR
14 ROBERT MINEMIER, SENTENCING
15 Defendant. V
/
16
TO THE CLERK OF THE ABOVE ENTITLED COURT: `
17
1, ROBERT AMPARAN, declare:
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I am an attorney licensed to practice in the State of
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California and before this Court and I am the attorney of record
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for defendant Robert Minemier in this matter.
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In the instant matter, on February 27, 2008, Mr. Minemier
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pled guilty to a misdemeanor violation of 36 U.S.C. §4.23(a)(l),
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driving under the influence of alcohol. This matter is y
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currently on calendar for Sentencing on June 10, 2008. This .
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declaration is submitted in support of a request that Mr. y
26
Minemier’s personal appearance be waived at that sentencing, and I
27 I
that he be allowed to participate via telephone or video
28
conference.
2

Case 3:07-cr—OO348—BZ Document 21 Filed 06/O2/2008 Page 3 of 3
1 The reason for this request is that Mr. Minemier has
2 relocated to Charlotte, North Carolina. Mr. Minemier is
3 currently unemployed, and traveling to San Francisco for the
4 sole purpose of appearing at this misdemeanor sentencing would
5 constitute a hardship.
6 1 have contacted United States Probation Officer Cheryl
7 Simone, who has informed me that the federal probation office in
8 North Carolina is ready, willing and able to immediately assume
9 supervision of Mr. Minemier’s misdemeanor probation. In
10 addition, Ms. Simone informs me that her office has no objection
11‘to Mr. Minemier appearing by telephone or videoconference,
12 rather than in person, at his sentencing.
13
14 1 declare under penalty of perjury that the foregoing is
15 true and correct, except as to matter herein stated on
16 information and belief, and, as to these matters, 1 believe them
17 to be true. This declaration is executed on June 2, 2008, at
18 San Francisco, California.
19 Signed: W
20
gsgRobert Amparangsg
21 ROBERT AMPARAN
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25 2
26 i
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28 i

Case 3:07-cr-00348-BZ

Document 21

Filed 06/02/2008

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Case 3:07-cr-00348-BZ

Document 21

Filed 06/02/2008

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Case 3:07-cr-00348-BZ

Document 21

Filed 06/02/2008

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