USA v. Stratton

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HEATHER E. WILLIAMS, #122664
Federal Defender
NOA E. OREN, #297100
Assistant Federal Defender
801 I Street, 3 rd Floor
Sacramento, CA 95814
Tel: 916-498-5700
Fax 916-498-5710
Attorney for Defendant
KY SIMERE STRATTON
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
vs.
KY SIMERE STRATTON,
Defendant.
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Case No. 2:25-cr-00222-DAD-1
UNOPPOSED MOTION AND [PROPOSED]
ORDER FOR SUBSTITUTION OF BOND AND
SURETY
Hon. Sean C. Riordan
IT IS HEREBY REQUESTED that the secured property bond involving the residence
owned by Michael Stratton, as ordered by the Honorable Jeremy D. Peterson to secure Mr.
Stratton’s pretrial release, be ordered substituted in light of the facts as presented below.
After a hearing on September 19, 2025, the Honorable Jeremy D. Peterson ordered Mr.
Stratton’s release on a $150,000.00 bond secured by the residence of his father, Michael Stratton.
See Dkt. 9, 16. On September 25, 2025, the collateral was received by the court, consistent with
the court’s order. See Dkt. 16. Given that the defendant’s father no longer wants to act as a
surety, and the defendant has no failures to appear in federal Court, has remained in compliance
and has not incurred any violations while subject to supervision, pre-trial services are
recommending the secured $150,000 bond posted by his father be substituted with an unsecured
bond in the amount of $50,000 to be co-signed by the defendant’s friend, Dayton Damar
Simpson.
Case 2:25-cr-00222-DAD Document 69 Filed 10/13/26 Page 1 of 3

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The government does not oppose the proposed substitution in bond and surety.
Dated: October 9, 2026 	Respectfully submitted,
HEATHER E. WILLIAMS
Federal Defender
/s/ Noa Oren
NOA OREN
Assistant Federal Defender
Attorney for KY SIMERE STRATTON
Case 2:25-cr-00222-DAD Document 69 Filed 10/13/26 Page 2 of 3

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ORDER
IT IS HEREBY ORDERED in Case No. 2:25-cr-00222-DAD-1 that the secured
$150,000 property bond involving the title of the residence owned by Michael Stratton, be
substituted with an unsecured bond in the amount of $50,000 to be co-signed by the
defendant’s friend, Dayton Damar Simpson.
Dated: October 9, 2026
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HON. SEAN C. RIORDAN
United States Magistrate Judge
Case 2:25-cr-00222-DAD Document 69 Filed 10/13/26 Page 3 of 3