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United States of America v. Nicole Louise Franks

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA,


March 14, 2011

UNITED STATES OF AMERICA
PLAINTIFF,
v.
NICOLE LOUISE FRANKS,
DEFENDANT

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

FRESNOREQUEST FOR AN EXTENSION OF TIME IN WHICH TO REPORT TO A DESIGNATED FEDERAL CORRECTIONAL INSTITUTION AND PROPOSED ORDER THEREON

NICOLE LOUISE FRANKS, by and through her appointed legal counsel, ANTHONY P. CAPOZZI, does hereby respectfully request an extension of time in which to report to the designated Federal Correctional Institution. The Defendant was sentenced on January 24, 2011 is scheduled to self-surrender on March 10, 2011 at 2:00 p.m.

This request is made pursuant to the fact that as of this date, the Defendant has yet to be designated to a facility. The Defendant currently resides in Oregon and requested a facility on the East Coast. She will need time to make travel arrangements once a designation is made.

In addition, the Defendant is three months pregnant and has a four month old infant at home. She has made arrangements for her family to relocate to an area near her designated facility to care for her infant daughter and the new baby after her surrender date. She will, however, need to be designated to a facility that will be able to support her medical needs while in custody.

Ms. FRANKS is requesting an opportunity to continue caring for her infant daughter and make travel/living arrangements for her family while decisions are made regarding her designation.

Therefore, Ms. FRANKS would request that her surrender date be continued.

Respectfully submitted, Dated: March 11, 2011 Anthony P. Capozzi, Attorney for NICOLE LOUISE FRANKS

ORDER

IT IS SO ORDERED. Good cause having been shown, the Defendant, NICOLE LOUISE FRANKS, is hereby granted an extension of time to report to the designated Federal Correctional Institution and her new date to report shall be April 21, 2011.

20110314

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