Filed: Jul. 03, 2019
Latest Update: Jul. 03, 2019
Summary: STIPULATION AND ORDER TO ALLOW DEFENDANT BARAJAS TO OBTAIN A PASSPORT AND TRAVEL TO MEXICO RICHARD F. BOULWARE, II , District Judge . IT IS HEREBY STIPULATED and AGREED by and between the United States of America, by and through NICHOLAS TRUTANICH, United States Attorney, and DANIEL SCHIESS, Assistant United States Attorney, and Defendant SERGIO BARAJAS, by and through his counsel, RUSSELL E. MARSH, ESQUIRE, and MONTI JORDANA LEVY, that the conditions of Mr. Barajas's Pretrial Release be mo
Summary: STIPULATION AND ORDER TO ALLOW DEFENDANT BARAJAS TO OBTAIN A PASSPORT AND TRAVEL TO MEXICO RICHARD F. BOULWARE, II , District Judge . IT IS HEREBY STIPULATED and AGREED by and between the United States of America, by and through NICHOLAS TRUTANICH, United States Attorney, and DANIEL SCHIESS, Assistant United States Attorney, and Defendant SERGIO BARAJAS, by and through his counsel, RUSSELL E. MARSH, ESQUIRE, and MONTI JORDANA LEVY, that the conditions of Mr. Barajas's Pretrial Release be mod..
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STIPULATION AND ORDER TO ALLOW DEFENDANT BARAJAS TO OBTAIN A PASSPORT AND TRAVEL TO MEXICO
RICHARD F. BOULWARE, II, District Judge.
IT IS HEREBY STIPULATED and AGREED by and between the United States of America, by and through NICHOLAS TRUTANICH, United States Attorney, and DANIEL SCHIESS, Assistant United States Attorney, and Defendant SERGIO BARAJAS, by and through his counsel, RUSSELL E. MARSH, ESQUIRE, and MONTI JORDANA LEVY, that the conditions of Mr. Barajas's Pretrial Release be modified to allow him to obtain his passport and travel to Mexico for up to 10 days in July 2019.
1. On October 4, 2017, Mr. Barajas appeared pursuant to a Summons, and was released on a PR Bond (ECF No.32). Mr. Barajas was ordered to surrender his passport and his travel was restricted to the continental U.S. (ECF No. 42 at 3).
2, Mr. Barajas's trial in this matter is currently set for December 2, 2019. (ECF No. 111
3. Mr. Barajas requests to travel to Mexico in July 2019 to celebrate his birthday with friends and family. He will need to retrieve his passport to travel out of the country.
4. The parties agree that the conditions of Mr. Barajas pretrial release be modified to allow him to travel to Mexico. This travel will take place between July 10-20, 2019. Mr. Barajas requests access to his passport for those dates. He will return the passport to U.S. Pretrial Services when he returns to the United States.
5. Pretrial Services agrees with these changes in Mr. Barajas' conditions of release. Mr. Barajas's Pretrial Services Officer is Camron Pitcher who is in California. Mr. Barajas and counsel have contacted Officer Pitcher, and he agrees with this request.
6. The parties agree that all other conditions of Mr. Barajas's release will remain in full force and effect.
Dated this 3rd day of July, 2019.
Respectfully submitted,
WRIGHT MARSH & LEVY UNITED STATES ATTORNEY
NICHOLAS TRUTANICH
BY /s/ Russell E. Marsh BY /s/ Daniel R. Schiess
RUSSELL E. MARSH, ESQUIRE DANIEL R. SCHIESS
MONTI JORDANA LEVY, ESQUIRE Assistant U.S. Attorney
Attorney for Defendant Sergio Barajas
ORDER
Based on the Stipulation between Defendant Sergio Barajas and the Government, through counsel, and good cause appearing,
IT IS HEREBY ORDERED that the conditions of Defendant Barajas's pretrial release be modified as follows:
1. Mr. Barajas may travel to Mexico for up to ten days between July 10-20, 2019.
2. Mr. Barajas will obtain his passport from U.S. Pretrial Services, who will provide the passport to him for the purpose of this travel. Mr. Barajas will return his passport to Pretrial Services when he is back in the United States.
3. All other conditions of Pretrial Supervision remain in effect.
IT IS SO ORDERED.
