Filed: Jul. 22, 2019
Latest Update: Jul. 22, 2019
Summary: STIPULATION AND ORDER TO AMEND SPECIAL CONDITIONS OF RELEASE CAROLYN K. DELANEY , Magistrate Judge . IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through James Conolly, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Erika Louise Schmid, that Ms. Schmid's Special Conditions of Release may be modified as follows: 1. Paragr
Summary: STIPULATION AND ORDER TO AMEND SPECIAL CONDITIONS OF RELEASE CAROLYN K. DELANEY , Magistrate Judge . IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through James Conolly, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Erika Louise Schmid, that Ms. Schmid's Special Conditions of Release may be modified as follows: 1. Paragra..
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STIPULATION AND ORDER TO AMEND SPECIAL CONDITIONS OF RELEASE
CAROLYN K. DELANEY, Magistrate Judge.
IT IS HEREBY STIPULATED and agreed by and between McGregor W. Scott, United States Attorney, through James Conolly, Assistant United States Attorney, counsel for Plaintiff, and Heather Williams, Federal Defender, through Assistant Federal Defender Christina Sinha, counsel for Defendant Erika Louise Schmid, that Ms. Schmid's Special Conditions of Release may be modified as follows:
1. Paragraph 2 of Ms. Schmid's current Special Conditions of Release governed her January 2019 release from custody. ECF No. 16. As this is now satisfied, it may be removed from her conditions.
2. Ms. Schmid's current Special Conditions of Release require her to remain inside her residence every day from 8:00 p.m. to 6:00 a.m., unless adjusted by a Pretrial Services officer. ECF No. 16 at paragraph 13. Her curfew may be modified so that she is required to remain inside her residence every day from 10:00 p.m. to 6:00 a.m., or as adjusted by the pretrial services officer.
i. The new condition will read as follows: "You must remain inside your residence every day from 10:00 p.m. to 6:00 a.m., or as adjusted by the pretrial services officer for medical, religious services, employment or court-ordered obligations." (This would become the new paragraph 12.)
2. Ms. Schmid's current Special Conditions of Release list Ms. Roxanna Hall as her third-party custodian. ECF No. 16 at paragraph 14. Her third party custodian may be modified to list Ms. Marki Humphrey as her custodian.
i. The new condition will read as follows: "You are released to the third-party custody of Marki Humphrey and you must reside with her in Milford, California, and not move or absent yourself from this residence for more than 24 hours without the prior approval of the pretrial services officer." (This would become the new paragraph 13.)
The government and Pretrial Services do not object to the modification.
The defense respectfully requests the Court to so modify the defendant's conditions of release and to issue the Amended Special Conditions of Release attached to this filing.
Respectfully submitted,
Dated: July 19, 2019 HEATHER E. WILLIAMS
Federal Defender
/s/Christina Sinha
CHRISTINA SINHA
Assistant Federal Defender
Attorneys for Defendant
ERIKA LOUISE SCHMID
Dated: July 19, 2019
MCGREGOR W. SCOTT
United States Attorney
/s/James Conolly
JAMES CONOLLY
Assistant United States Attorney
Attorney for Plaintiff
ORDER
The Court, having received and considered the parties' stipulation, and good cause appearing therefrom, adopts the parties' stipulation in its entirety as its order.
IT IS SO ORDERED.
