UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
September 9, 2011
UNITED STATES OF AMERICA,
DANNY PEREDA, DEFENDANT.
REQUEST AND [PROPOSED] ORDER
FOR TELEPHONIC APPEARANCE AT
STATUS HEARING, SEPTEMBER 19, 2011 CALENDAR
Now Comes Gail Shifman, counsel for Defendant DANNY PEREDA, who hereby declares under penalty of perjury as follows:
1. I am court appointed counsel for Defendant Danny Pereda in this matter who appeared in this matter August 11, 2011. The case is currently scheduled for a Status Hearing on September 19, 2011 at 8:30 a.m.
2. I am requesting permission to appear telephonically at the Status Hearing because I will be having knee surgery on September 13, 2011 and will be unable to be physically present in Court for the status hearing. I am filing this request just after being advised of the scheduled date and time of my knee surgery. Though I believe this is an unusual request in a criminal case, I am seeking permission to participate telephonically because this is the initial appearance before the Court of all of the defendants in the case. Schedules and dates may be discussed at this hearing as well as other issues where my participation may be helpful. If this request is granted, at the time of the hearing Counsel can be reached at telephone number 415/816-3640.
3. If it is not possible to participate telephonically, I will have counsel specially appear for me for purposes of this hearing.
4. Mr. Pereda has been advised that I am seeking permission to appear telephonically and he is in agreement with this request. He understands that if I'm not able to participate telephonically that counsel will specially appear on his behalf for this hearing and he has no objection to the special appearance.
I declare under penalty of perjury that the foregoing is true and correct and if stated on information and belief, I believe it to be true. Signed this 8th day of September, 2011 in San Francisco, California.
/s/ Gail Shifman GAIL SHIFMAN Attorney for Defendant DANNY PEREDA
The court is uncertain whether a telephonic appearance is permissible in a criminal case. Accordingly, counsel may specially appear for Ms. Shifman for purposes of this hearing.
IT IS SO ORDERED.
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