Filed: Feb. 07, 2013
Latest Update: Feb. 07, 2013
Summary: MOTION TO MODIFY CONDITIONS OF RELEASE AND PROPOSED ORDER THEREON CARL W. HOFFMAN, Magistrate Judge. Comes now, the defendant, LIZBETH PINEDA, by and through her counsel of record, Victor Manuel Torres, and files his Motion to Modify Conditions of Release to allow Ms. Pineda to travel to Lafayette, Indiana to visit her cousin beginning February 9, 2013, until February 23, 2013; Ms. Pineda will then travel to Clearwater, Florida to visit friends of her family and returning to Las Vegas on March
Summary: MOTION TO MODIFY CONDITIONS OF RELEASE AND PROPOSED ORDER THEREON CARL W. HOFFMAN, Magistrate Judge. Comes now, the defendant, LIZBETH PINEDA, by and through her counsel of record, Victor Manuel Torres, and files his Motion to Modify Conditions of Release to allow Ms. Pineda to travel to Lafayette, Indiana to visit her cousin beginning February 9, 2013, until February 23, 2013; Ms. Pineda will then travel to Clearwater, Florida to visit friends of her family and returning to Las Vegas on March ..
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MOTION TO MODIFY CONDITIONS OF RELEASE AND PROPOSED ORDER THEREON
CARL W. HOFFMAN, Magistrate Judge.
Comes now, the defendant, LIZBETH PINEDA, by and through her counsel of record, Victor Manuel Torres, and files his Motion to Modify Conditions of Release to allow Ms. Pineda to travel to Lafayette, Indiana to visit her cousin beginning February 9, 2013, until February 23, 2013; Ms. Pineda will then travel to Clearwater, Florida to visit friends of her family and returning to Las Vegas on March 9, 2013.
The date currently set for her sentencing is March 5, 2013, but defense counsel is seeking to continue the hearing until March 19, 2013. This request is based upon the following points and authorities.
DATED: February 7, 2013 Respectfully submitted,
s/____________________________
VICTOR MANUEL TORRES
Attorney for Ms. PINEDA
POINTS AND AUTHORITIES
The defendant, Lizbeth Pineda, initially appeared before the Court on June 11, 2012. Ms. Pineda was released from custody on her own recognizance with a condition, among others, that she not travel outside the District of Nevada.
Ms. Pineda spoke to her supervising U.S. Pretrial Services Officer Allison McCurty about travelling to visit her relatives and friends in Indiana and Florida. Ms. Pineda will be visiting Manuel Sanchez, who lives at 3211 Kingsmill Court, Lafayette, IN 47909 and his telephone number is (803 Camarillo, who lives at 1280 Lakeview Road, Lot 123, Clearwater, FL 33756 and her telephone number is (727
Ms. McCurty has indicated to counsel that she is not opposed to this request. Ms. Pineda has maintained an excellent record of compliance with Pretrial Services and responsive to counsel and U.S. Probation at all times.
An exchange of e-mails between defense counsel Assistant U.S. Attorney Andrew Duncan concerning this request indicated Mr. Duncan does not oppose this request either.
CONCLUSION
For the foregoing reasons, the undersigned respectfully requests that this Court allow Ms. Pineda to travel to Indiana and Florida for the purpose of visiting family and friends before she is sentenced.
DATED: February 7, 2013 Respectfully submitted,
/s/___________________________
VICTOR MANUEL TORRES
Attorney for Ms. Pineda
ORDER TO MODIFY CONDITIONS OF PRETRIAL RELEASE
The Court being advised in the defendant's motion of the reasons for the request and for good cause thereon appearing,
IT IS HEREBY ORDERED, ADJUDGED AND DECREED that the Motion to Modify Conditions of Pretrial Release to permit travel to Indiana and Florida from February 9, 2013 through March 9. 2013 is GRANTED.
