STIPULATION AND [PROPOSED] ORDER TO ALLOW DEFENDANT TO TRAVEL TO MEXICO

ALLISON CLAIRE, Magistrate Judge.

STIPULATION

Plaintiff, United States of America, by and through its counsel, Assistant United States Attorney Brian Fogerty, and Defendant, Sandra Hermosillo, by and through her counsel, Erin J. Radekin, hereby stipulate that Ms. Hermosillo may, with the permission of her pretrial services officer, and pursuant to such conditions as required by her pre-trial services officer, travel to Mexicali, Mexico at any time between the dates of March 2, 2017 and March 6, 2017 to visit her father, who is in hospice care after being hospitalized for pneumonia and may not recover. Ms. Hermosillo has traveled to Mexico to visit family on six prior occasions while on pretrial release in this case, and there have been no reported violations of the court-imposed travel conditions.

It is further stipulated that pretrial services shall return Ms. Hermosillo's passport to her on the date of the filing of the proposed order to permit Ms. Hermosillo to travel to Mexico on or after March 2, 2017. Ms. Hermosillo must return to the United States by March 6, 2017 and must check in with and surrender her passport to her pretrial services officer within 24 hours of returning to the United States, but in no event later than March 7, 2017.

Accordingly, the parties respectfully request the Court adopt this proposed stipulation.

IT IS SO STIPULATED.

IT IS SO ORDERED.