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United States v. Contreras

IN THE UNITED STATES DISTRICT COURT IN AND FOR THE EASTERN DISTRICT OF CALIFORNIA


November 7, 2008

UNITED STATES OF AMERICA, PLAINTIFF,
v.
RUBEN CONTRERAS DEFENDANT.

The opinion of the court was delivered by: Oliver W. Wanger, Judge United States District Court

EX PARTE MOTION TO EXONERATE PROPERTY BOND; DECLARATION; ORDER THEREON

Judge: Hon. Oliver W. Wanger

This Court pronounced Judgment in this case on May 5, 2008. Defendant RUBEN CONTRERAS, hereinafter referred to as DEFENDANT, was sentenced to fifteen (15) months in custody, pursuant to his plea agreement, with credit for time served, in a confinement center and placed on twelve (12) months of supervised release. On February 21, 2008, DEFENDANT was ordered released, pending his sentencing on this matter.

A property bond was provided to the Court as a condition of DEFENDANT'S release prior to sentencing. The property bond included two separate Promissory Notes. One Note was executed by Ruben Ramos Contreras, DEFENDANT'S father and another Note was executed by Andrea Padilla, DEFENDANT'S mother. Each note was for $300,000 and both notes were secured by a Deed of Trust on each of the parents separate and respective property.

Pursuant to the May 5, 2008 judgment, DEFENDANT was to surrender himself on May 15, 2008 to complete his sentence. DEFENDANT did surrender himself on May 15, 2008 and has now completed his full sentence, pursuant to the judgment and the plea agreement.

It is respectfully requested that the property bond be exonerated.

Dated: October 30, 2008

DANIEL L. HARRALSON, ESQ. Attorney for Defendant RUBEN CONTRERAS

DECLARATION OF DANIEL L. HARRALSON

I, DANIEL L. HARRALSON, Esq., declare as follows:

1. I am an attorney at law, licensed to practice in the Courts of the State of California and in Federal Courts of the United States; I am the attorney representing RUBEN CONTRERAS in this case. I have represented him since March 28, 2007.

2. On February 21, 2008, DEFENDANT RUBEN CONTRERAS, was ordered released on a property bond in the amount of $300,000.00. The property bond was secured by Promissory Notes and Deeds of Trust.

3. On May 5, 2008, DEFENDANT was sentenced to fifteen (15) months, with credit for time served.

4. DEFENDANT has completed his sentenced and has been released.

I declare under penalty of perjury that the foregoing is true and correct. This declaration is executed on October 30, 2008, at Fresno, California.

Daniel L. Harralson, Esq.

ORDER IT IS SO ORDERED. The property bond in the amount of $300,000.00 is hereby exonerated. A Deed of Reconveyance for The Deeds of Trusts, securing the Notes should be executed and filed in the appropriate County Recorders Office.

20081107

© 1992-2008 VersusLaw Inc.



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