STIPULATION TO MODIFY PRETRIAL RELEASE CONDITIONS; DECLARATION OF PETER M. JONES; AND ORDER THEREON

BARBARA A. McAULIFFE, Magistrate Judge.

Defendant, LOUIE CALLES, by and through counsel, Peter M. Jones, and Plaintiff, UNITED STATES OF AMERICA, by and through counsel, Benjamin B. Wagner hereby stipulate as follows:

That the condition of Pretrial Release regarding Defendants' travel be modified to reflect the following: Defendant may travel to the State of Colorado to spend the Christmas Holiday with his daughter, Nicole Calles, who is expecting the birth of Mr. Calles' first grandchild during the Christmas Holidays. Defendant is to leave no earlier than Wednesday, December 18, 2013, and return to Fresno no later than Wednesday, January 1, 2014; all other conditions of release, not in conflict, shall remain in full force and effect.

DECLARATION OF PETER M. JONES

I, Peter M. Jones, declare as follows:

1. I am an attorney admitted to practice before this court, and am counsel of record for Louie Calles, a Defendant in the above-entitled action.

2. Mr. Calles informed me that he would like to spend Christmas with his daughter, Nicole Calles, and be with her when his first grandchild is born. The expected delivery date is during the Christmas Holiday.

3. Mr. Calles currently resides in Fresno, CA and is being supervised by pre-trial release. His daughter, Nicole Calles, resides in Centennial, Colorado.

4. I have contacted Pretrial Release Officer, Jacob Scott, and informed him of Mr. Calle's desire to travel to Colorado. Officer Scott informed me that he had no opposition to Mr. Calle's traveling to Colorado as stipulated.*

5. I have contacted AUSA Grant Rabenn, and he has agreed to stipulate to the Defendant's travel request provided there are specific departure and return dates.

I declare under penalty of perjury that the foregoing is true and that this declaration was executed in Fresno, California, on December 6, 2013.

ORDER

Having reviewed the above Stipulation and Good Cause Appearing, it is hereby ordered that the travel condition of Pretrial Release regarding Defendant, Louie Calles, be modified as follows: He may travel to the State of Colorado to spend the Christmas Holiday with his daughter, Nicole Calles. He will leave no earlier than Wednesday, December 18, 2013 and return to Fresno, CA no later than Wednesday, January 1, 2014. All other conditions of release, not in conflict, shall remain in full force and effect.

IT IS SO ORDERED.