Free Proposed Order - District Court of California - California

Case 3:07-cr-00307-PJH

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Filed 04/14/2008

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JOSEPH P. RUSSONIELLO (CSBN 44332) United States Attorney BRIAN J. STRETCH (CSBN 163973) Chief, Criminal Division KYLE F. WALDINGER (ILSB 6238304) Assistant United States Attorney 450 Golden Gate Avenue, 11th Floor San Francisco, California 94102 Telephone: (415) 436-6830 Facsimile: (415) 436-7234 Attorneys for Plaintiff UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION UNITED STATES OF AMERICA, Plaintiff, v. THOMAS DAVID HAGBERG, Defendant. ) ) ) ) ) ) ) ) ) ) ) No. CR 07-0307 PJH UNITED STATES' UNOPPOSED REQUEST TO CONTINUE SUPERVISED RELEASE HEARING AND [PROPOSED] ORDER

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The United States hereby submits this request to continue the supervised release hearing currently sent for April 16, 2008, at 2:30 p.m. Neither the defense counsel nor the Probation Officer have an objection to this request. In support of this request, the United States states as follows: 1. The parties last appeared on February 27, 2008. At that time, the parties

jointly requested that the matter be put over to April 16, 2008 for status, in part to determine whether the defendant would continue to take prescribed medications and otherwise remain in compliance with the conditions of supervised release. 2. The United States recently inquired of defense counsel, Federal Public

Defender Barry Portman, and the assigned Probation Officer, Sharon Alberts, whether they would object to continuing the April 16 hearing for approximately one month, based
USA'S UNOPPOSED REQUEST TO CONTINUE & [PROPOSED] ORDER CR 07-0307 PJH

Case 3:07-cr-00307-PJH

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Filed 04/14/2008

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on government counsel's need to prepare for a trial scheduled to commence in San Jose on April 21, 2008 before The Honorable Ronald M. Whyte. Both Mr. Portman and Ms. Alberts indicated that they had no objection to a continuance to May 21, 2008, at 2:30 p.m.; Mr. Portman advised that he would be out of the office when this request was submitted and that government counsel was authorized to represent his position to the Court. 3. Although the April 21 trial may be continued to April 29, the Probation

Officer has already advised the defendant that he would likely need not travel to San Francisco on April 16. 4. For all of these reasons, the United States respectfully requests that the

Court continue the hearing currently set for April 16, 2008, at 2:30 p.m., to May 21, 2008, at 2:30 p.m.

DATED:

4/14/2008

JOSEPH P. RUSSONIELLO United States Attorney

___________/s/_________________ KYLE F. WALDINGER Assistant United States Attorney

ORDER For the reasons state above, the supervised release hearing currently set for April 16, 2008, at 2:30 p.m., is continued to May 21, 2008, at 2:30 p.m. SO ORDERED.

DATED:________________

_______________________________ PHYLLIS J. HAMILTON United States District Judge

USA'S UNOPPOSED REQUEST TO CONTINUE & [PROPOSED] ORDER CR 07-0307 PJH -2-