USA v. Tolentino et al

[PROPOSED] STIPULATED ORDER
PACK, CR 247-DJC
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JODI LINKER
Federal Public Defender
Northern District of California
ANA BOTELLO AZ Bar#030528
Assistant Federal Public Defender
19th Floor Federal Building - Box 36106
450 Golden Gate Avenue
San Francisco, CA 94102
Telephone: 	(415) 436-7700
Facsimile: 	(415) 436-7706
Email: 	ana_botello@fd.org
Counsel for Defendant Pack
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JESSICA PACK,
Defendant.
Case No.: CR 2:25-00247-DJC-8
STIPULATION 	AND 	[PROPOSED]
ORDER 	TO 	CONTINUE
ARRAIGNMENT AND DETENTION
HEARING
1. 	By previous order this case was set for detention hearing on November 4, 2025.
2. 	By this Stipulation the defendant asks to move both the initial and detention hearing to
November 7, 2025 and for counsel to appear via video.
3. 	The parties agree and stipulate, and request that the Court find the following: (a)
Counsel for the defendant has not been able to speak with her client. Thursday,
November 6, 2025, is the earliest that that can occur. That is also the date Pretrial
Services will 	first 	be 	able 	to interview 	Ms. 	Pack 	for 	purposes 	of 	making 	a
recommendation.

[PROPOSED] STIPULATED ORDER
PACK, CR 247-DJC
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(b) Counsel for the defendant believe failure to grant the above-requested continuance
would deny them the reasonable time necessary for effective preparation, taking into
account the exercise of due diligence. (c) The government does not object to the
continuance.
IT IS SO STIPULATED.
August 4, 2025 	ERIC GRANT
Dated 	United States Attorney
Eastern District of California
/S
ROBERT ABENDROTH
Assistant United States Attorney
August 4, 2025 	JODI LINKER
Dated 	Federal Public Defender
Northern District of California
/S
ANA BOTELLO
Assistant Federal Public Defender

[PROPOSED] STIPULATED ORDER
PACK, CR 247-DJC
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[PROPOSED] ORDER
Good cause appearing, the hearing set for November 4, 2025 is vacated. The
Arraignment and detention hearing is reset for November 7, 2025.
IT IS SO ORDERED.
DATED: November 4, 2025