DECLARATION AND [PROPOSED] ORDER FOR MODIFICATION OF PRE-TRIAL RELEASE

EDWARD M. CHEN, District Judge.

DECLARATION OF COUNSEL

I, COLIN COOPER, declare as follows:

1. I am a partner in the COOPER LAW OFFICES, and I am the attorney of record for defendant AISHAH BUENAVENTURA.

2. Ms. BUENAVENTURA'S current conditions of release include the restriction that her travel be limited to the Northern District of California.

3. Ms. BUENAVENTURA is requesting permission to travel outside of the Northern District to the Eastern District, to Vallejo, California, in order to visit her daughter's gravesite at "All Souls Cemetery" located at 550 Glen Cove Road, Vallejo, California, 94590. Ms. BUENAVENTURA would like to visit her daughter's gravesite once or twice a month.

4. I have discussed this with AUSA Julie Garcia, the AUSA assigned to this case. Ms. Garcia has no objection to this request. I have also discussed this with United States Pretrial Services Officer Timothy Elder who also does not object to the request.

5. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief and is executed this 24th day of July, 2018, in the city of Berkeley, County of Alameda, State of California.

[PROPOSED] ORDER FOR MODIFICATION OF PRE-TRIAL RELEASE

GOOD CAUSE APPEARING it is ordered that Ms. BUENAVENTURA'S conditions of pretrial release are modified permitting Ms. BUENAVENTURA to travel to Vallejo, California, to visit her daughter's gravesite located at All Souls Cemetery at 550 Glen Cove Road, Vallejo, California, 94590.