     1    1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  HEATHER E. WILLIAMS, Bar #122664    Federal Defender ERIC V. KERSTEN, Bar #226429 Assistant Federal Defender Designated Counsel for Service 2300 Tulare Street, Suite 330 Fresno, California 93721-2226 Telephone: (559) 487-5561  Attorney for Defendant LADONNA LEE MOON       IN THE UNITED STATES DISTRICT COURT    FOR THE EASTERN DISTRICT OF CALIFORNIA       UNITED STATES OF AMERICA,  Plaintiff,  vs.  LADONNA LEE MOON,  Defendant.   ) ) ) ) ) ) ) ) ) ) ) ) )  Case No. 1:13-CR-00362 AWI-BAM-5  OPPOSED APPLICATION FOR ORDER EXTENDING SURRENDER DATE; ORDER    Judge: Hon. Anthony W. Ishii       Defendant Ladonna Lee Moon hereby requests an extension of time for her surrender to  the United States Bureau of Prisons, to commence service of her term of incarceration.  Ms. Moon was convicted at trial and has filed her timely notice of appeal. She is  currently preparing a motion for release pending appeal, which will be filed with this court no  later than April 22, 2016. Because this court hears criminal law and motion on the second and  fourth Mondays of the month, the earliest possible hearing date for Ms. Moon's motion for  release pending appeal is May 9, 2016, which is also her current surrender date. Ms. Moon is  requesting a short stay of her surrender date, to May 16, 2016, or one week after the court rules  on her motion for release pending appeal, whichever date is later. This extension is requested to  allow time for the court to rule on defendant’s motion for release pending appeal, and to allow    Case 1:13-cr-00362-AWI-BAM Document 461 Filed 04/25/16 Page 1 of 3