United States of America v. In The Matter of the Extradition of Carl Stephen Kaminski

Filing 38

STIPULATION and ORDER to continue extradition briefing and hearing from 5/21/2014 to 6/25/2014 at 09:00 AM in Courtroom 9 (SAB) before Magistrate Judge Stanley A. Boone. Signed by Magistrate Judge Stanley A. Boone on 5/19/2014. (Hernandez, M)

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BENJAMIN B. WAGNER
United States Attorney
MICHAEL G. TIERNEY
Assistant United States Attorney
2500 Tulare Street, Suite 4401
Fresno, California 93721
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for United States of America
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IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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CASE NO. 1:13-MC-00029-GSA

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IN THE MATTER OF THE EXTRADITION OF
CARL STEPHEN KAMINSKI

STIPULATION AND ORDER TO CONTINUE
EXTRADITION BRIEFINGS

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BACKGROUND

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On April 2, 2014, the Court approved the parties’ request to 1) suspend a previously-ordered

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briefing schedule related to probable cause issues and 2) set a status conference during the final two

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weeks of May. The Court set the status conference for May 21, 2014 at 9:00 a.m.

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Following the Court’s order, Government counsel worked with representatives of the U.S. State

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Department, the Justice Department’s Office of International Affairs (OIA), and Albanian Foreign

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Ministry and Justice officials to determine whether Albania wished to submit additional materials

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relating to the age of the minor victims at the time of the abuse. As a result of these initial contacts,

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Government counsel, as well as U.S. State and Justice Department personnel, were able to engage in an

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extended conversation on May 13, 2014 with the local Albanian prosecutor assigned to Kaminski’s case,

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Vladimir Mara, Esq.

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Mara offered to submit documentation clarifying the ages of the minor victims at the time of

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Kaminski’s abuse. However, he indicated that he would not be authorized to send such documentation

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without a formal request from the United States sent through the Albanian Foreign Ministry to the

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Albanian Ministry of Justice.

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The OIA attorney assigned to this matter transmitted that request on May 14, 2014. He has
advised Government counsel that responses to such requests usually take four to five weeks.
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Accordingly, the Government proposes that the status conference currently set for May 21, 2014 be

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continued until the week of June 23, 2014, at a time convenient to the Court.
Government counsel spoke with Kaminski’s counsel on May 16, 2014, and Kaminski’s counsel

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agrees to a continuation of the status conference until the week of June 23.

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STIPULATION AND ORDER

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IT IS HEREBY STIPULATED by and between the parties hereto, and through their respective
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attorneys of record herein, that the status conference currently set for May 21, 2014 be continued to June 25,
2014 at 9:00 a.m. before Magistrate Judge Stanley A. Boone.

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Respectfully submitted,

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BENJAMIN B. WAGNER
United States Attorney

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DATED: May 16, 2014

By:

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/s/ Michael G. Tierney _____ ______
Michael G. Tierney
Assistant United States Attorney

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HEATHER E. WILLIAMS
Federal Defender

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DATED: May 16, 2014

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By:

/s/ Victor Chavez______
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VICTOR CHAVEZ
Assistant Federal Defender
Attorney for Carl Stephen Kaminski

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ORDER
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IT IS SO ORDERED.
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Dated:

May 19, 2014
UNITED STATES MAGISTRATE JUDGE

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