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U.S. v. KARAPETYAN, 2:16-cr-230-GMN-CWH. (2017)

Court: District Court, D. Nevada Number: infdco20170721c05 Visitors: 10
Filed: Jul. 20, 2017
Latest Update: Jul. 20, 2017
Summary: DEFENDANT VAGE KARAPETYAN'S UNOPPOSED MOTION AND [PROPOSED] ORDER TO PERMIT DEFENDANT TO TRAVEL TO THE STATE OF CALIFORNIA FROM 7/24/2017 TO 7/30/2017 CARL W. HOFFMAN , Magistrate Judge . NOW COMES Defendant VAGE KARAPETYAN, by and through FRANK H. COFER III, ESQ. of COFER & GELLER, LLC, and hereby moves this Honorable Court to temporarily permit Defendant to travel to the State of California during the dates of 7/24/2017 to 7/30/2017 so that he can celebrate his mother-in-law's birthday wi
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DEFENDANT VAGE KARAPETYAN'S UNOPPOSED MOTION AND [PROPOSED] ORDER TO PERMIT DEFENDANT TO TRAVEL TO THE STATE OF CALIFORNIA FROM 7/24/2017 TO 7/30/2017

NOW COMES Defendant VAGE KARAPETYAN, by and through FRANK H. COFER III, ESQ. of COFER & GELLER, LLC, and hereby moves this Honorable Court to temporarily permit Defendant to travel to the State of California during the dates of 7/24/2017 to 7/30/2017 so that he can celebrate his mother-in-law's birthday with family. This is the defendant's fourth request for a temporary relaxation of his terms of pretrial release.

This motion is unopposed by the U.S. Attorney's office and is unopposed by pretrial services, and is made and based on all the papers and pleadings on file herein and the declaration of counsel filed herewith.

FRANK H. COFER III, ESQ., makes the following declaration:

1. I am an attorney licensed to practice law in all state courts in the State of Nevada, before the United States District Courts in the district of Nevada, and before the Ninth Circuit Court of Appeals.

2. I am retained to represent Defendant VAGE KARAPETYAN in the instant action and am making this declaration in support of DEFENDANT VAGE KARAPETYAN'S UNOPPOSED MOTION AND [PROPOSED] ORDER TO PERMIT DEFENDANT TO TRAVEL TO THE STATE OF CALIFORNIA FROM 7/24/2017 TO 7/30/2017 that is filed herewith. I have personal knowledge and am competent to testify to the matters stated herein.

3. I am informed and I believe that my client, Defendant VAGE KARAPETYAN, wishes to travel to Los Angeles, California in order to celebrate his mother-in-law's birthday with family during the dates of 7/24/2017 to 7/30/2017. However, his current conditions of release prohibit him from traveling outside of the State of Nevada.

4. I have communicated with U.S. Pretrial Services employee SAMIRA BARLOW (responsible for supervising the defendant) and AUSA ROBERT KNIEF (responsible for prosecuting this case) regarding this matter. Both of these individuals have indicated that they have no opposition to the instant motion.

5. I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing is true and correct except as to those matters stated herein upon information and belief.

ORDER

THIS MATTER having come before the Court via an unopposed motion, and good cause appearing therefor,

IT IS HEREBY ORDERED that the conditions of pretrial release as to Defendant VAGE KARAPETYAN are temporarily modified in order to permit him to travel to the State of California during and throughout the following dates only: Monday, July 24, 2017 through Sunday, July 30, 2017.

Source:  Leagle

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