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United States of America v. Necole Ward

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


June 30, 2011

UNITED STATES OF AMERICA, PLAINTIFF,
v.
NECOLE WARD,
DEFENDANT.

The opinion of the court was delivered by: Judge: Morrison C. England, Jr.

Time: at 9:00 a.m.

MOTION TO DELAY MS. WARD'S SELF-SURRENDER DATE FROM JULY 14, 2011 TO SEPTEMBER 1, 2011

The Defendant, Necole Ward, by her attorney, Bruce Locke, moves the Court to delay her self-surrender date from July 14, 2011 to September 1, 2011. The reason for the request to delay the surrender date is that Ms. Ward has a one-year old infant and her only daycare while she is incarcerated is her mother-in-law. That mother-in-law is having surgery for a hysterectomy on July 14, 2011 and she will need time to recover from that surgery before she will be able to care for the one-year old. Undersigned counsel believes that if the defendant had known about the surgery at the time of her sentencing, the Court would have granted the defendant the additional time to self-surrender. This is not a Motion made just to delay the serving of the sentence.

Undersigned counsel has requested that the government join in this Motion but the government has declined to join and will oppose the Motion. A propose order is submitted herewith.

DATED: June 27, 2011

BRUCE LOCKE Attorney for Necole Ward BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Ste 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for NECOLE WARD

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, No. 2:09-cr-00037-MCE Plaintiff, ORDER v. NECOLE WARD, Defendant.

For good cause shown, and upon no objection from the Government, the Defendant's Motion to delay her self-surrender from July 14, 2011 to September 1, 2011 is hereby granted and the defendant is ordered to self-surrender to the place designated by the Bureau of Prisons by 2:00 p.m., on September 1, 2011.

IT IS SO ORDERED. Dated: June 30, 2011

20110630

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