AMENDED STIPULATION AND [PROPOSED] ORDER TO ALLOW DEFENDANT TO TRAVEL TO MEXICO TO VISIT HER FATHER STIPULATION

ALLISON CLAIRE, Magistrate Judge.

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 June 8, 2016 and June 18, 2016 to visit her father, who resides in Mexicali, Mexico. Her father is elderly and has multiple health problems. Ms. Hermosillo has traveled to Mexico to visit her father on four 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 June 8, 2016. Ms. Hermosillo must return to the United States by June 18, 2016 and must check in with and surrender her passport to her pretrial services officer on the next day on which the Court is open, June 20, 2016.

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

IT IS SO STIPULATED.

IT IS SO ORDERED.