IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 13, 2011
UNITED STATES OF AMERICA,
JEFF BARNES DEFENDANT.
The opinion of the court was delivered by: Judge: Hon. John A. Mendez
MARK J. REICHEL, State Bar THE 455 CAPITOL LAW OFFICES OF REICHEL #155034 Sacramento, MALL, 3rd FLOOR, Suite 350 & PLESSER California 95814 Telephone: (916) 498-9258 (916) 441-6553 www.reichellaw.com Attorney JEFF BARNES for Defendant FAX: email@example.com
ORDER CONTINUING DATE FOR SELF SURRENDER
Defendant, JEFFREY BARNES, through his attorney, hereby requests an Order re setting the date for his self surrender of sentence to February 18, 2011.
Grounds for request: Mr. Banes's mother, Linda Barnes, as referenced in the Probation Report, is undergoing chemotherapy treatment for advanced liver cancer. She begins her chemotherapy on Jan 19, 2011. Mr. Barnes is her only care provider, her only means of transportation, and the sole person she relies on for assistance of all her daily needs.
Order extending date for self surrender
After his sentencing, Mr. Barnes spent almost a month screening qualified applicants to find a caregiver who could take care of his mother, get her to her Chemotherapy appointments and all her other appointments, and provide her the necessary care and help she needs. A woman named Jennie was hired. She was fired last week when she was caught stealing medication and jewelry within the first month of her new duties. Jeannie had been employed with Ms. Barnes part time as a cleaning person and had never had any issues regarding theft.
Mr. Barnes is now trying to find a friend or relative who can step in and provide the assistance.
As well, the permanent long term care of Ms. Barnes, as well as addressing her immediate financial needs during her illness, involves Jeff Barnes' current job. He is currently rehabilitating a double wide mobile home on 3 acres, which he is being paid to remodel, as well as being granted the opportunity for Ms. Barnes to be the long term tenant. He has been working part time on the dwelling for 10 weeks now, and still has about 3 weeks to go. As soon as the repairs are complete, he will be moving his mother in. It will be a safer, more affordable place of residence for Ms. Barnes while she battles her cancer.
She begins her Chemotherapy program Jan 19th, and it will last 8 to 12 weeks depending on how she is responding to treatment. The caretaker will need to assist in that entire time period. Mr. Barnes desires to find a qualified person in the next few weeks and hand the duties off to that person at that time.
Mr. Barnes's was sentenced to a period of 18 months, and was ordered to self surrender on January 14, 2011.
ORDER IT IS SO ORDERED. The date for self surrender is extended to February 18, 2011. All prior terms and conditions of sentencing and release shall remain in full force and effect.
THE HONORABLE JOHN A. MENDEZ United States District Court
Stip and Order 3
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