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California Cases January 03, 2023: United States v. Hall

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Court: U.S. District Court — Eastern District of California
Date: Jan. 3, 2023

Case Description

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UNITED STATES OF AMERICA, Plaintiff,
v.
TAKIYAH HALL Defendant.

No. 1:21-cr-00282-JLT-SKO

United States District Court, E.D. California

January 3, 2023

HEATHER E. WILLIAMS,

ERIC V. KERSTEN

DEFENDANT'S UNOPPOSED MOTION TO EXTEND SURRENDER DATE; ORDER

BARBARA A. MCAULIFFE, UNITED STATES MAGISTRATE JUDGE

Defendant Takiyah Hall, by her attorney of record, Assistant Federal Defender, Eric Kersten, hereby moves the Court for a three-day continuance of her surrender date, presently set for January 3, 2023. Ms. Hall respectfully submits that this continuance is in the best interests of justice for the following reasons.

Ms. Hall resides in Fresno with her three juvenile children, twin daughters, age 16, and a 12 year old son. Currently, Hall and her children reside with Takiyah's mother, Tamela Hall, and her grandmother, Mary Grant. However, Tamela Hall just started chemotherapy the week before Christmas, and Mary Grant is 92 years old. For these reasons neither is an ideal candidate to care for Takiyah Hall's children while she in custody. Robert Cardenas, the father of Ms. Hall's older children, resides in Oklahoma and will be traveling to Fresno on Friday, January 6, 2003 to pick up all three children and take them to Oklahoma, where they will reside with Mr. Cardenas while

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Hall is in custody. Given the inability of Mary Grant and Tamela hall to adequately care for Takiyah Hall's children at this time, a short, three day extension of Ms. Hall's surrender date, is requested. Specifically, Ms. Hall requests that the Court continue her surrender date from Tuesday, January 3, 2023, to Friday, January 6, 2023 at 2:00 pm

Counsel for Ms. Hall has discussed this matter with AUSA Alexandre Dempsey and is informed that the government does not oppose this brief continuance of Ms. Hall's surrender date. Counsel has also spoken with PTS Officer Jessica McConville who has advised that Ms. Hall has submitted clean, urinalysis tests on two occasions since her last court date, and that Pretrial Services makes no position on this request.

ORDER

IT IS SO ORDERED. Takiyah Hall shall surrender to the United States Marshals on or before Friday, January 6, 2023, at 2:00 pm.

IT IS SO ORDERED.