STIPULATION OF COUNSEL AND ORDER TO MODIFY CONDITIONS OF RELEASE

SHEILA K. OBERTO, District Judge.

To the Honorable Sheila K. Oberto, Magistrate Judge in the United States Court for the Eastern District of California.

Counsel for the defendant, Laimiro Bobadilla and Counsel for the Plaintiff, the United States Government, through Assistant United States Attorney, Rabenn Vincenza, do hereby Stipulate that the Order regarding Pretrial Release Conditions for Laimiro Bobadilla be modified.

On July 16, 2018, a detention hearing was held in the above captioned matter. Pre-Trial Release Officer (PTO) recommended the defendant's release, in finding that there were conditions of release which can sufficiently mitigate the defendant's risk of non-appearance and the risks of danger. The PTO further recommended a financial commitment be made. The Honorable Erica P. Grosjean ordered Mr. Bobadilla released as follows: $50,000.00 total equity property bond; third-party custody; do not obtain a passport or travel document during the pendency of these proceedings; and all other conditions as read into the record.

It has been revealed upon further investigation that Ms. Hinsunza's property does not have $50,000 in equity as anticipated. Mr. Bobadilla's family has offered a different property with $100,000 in equity owned by family member, Juventino Ramos Rosas. Mr. Ramos is willing to put up title to his home to effectuate the release of his nephew Liamiro Bobadilla on Pre-trial release.

On August 17, 2018, I notified Assistant U.S. Attorney Rabenn Vincenza of this request and she did not state any opposition to the request and indicated that she would defer to the court.

On August 17, 2018, I notified Pre-Trial Services Duty Officer, Mary and she stated that they are fine with whatever the government and defense counsel agree on.

Therefore, Counsel would stipulate and request that Order (7)(1) Condition of Release requirement that a total equity property bond, not less than $50,000, secured by property owned by Silvia Hinsunza, be modified from the previously Ordered Conditions to allow for a total equity property bond, of not less than $100,000, secured by property owned by Juventino Ramos Rosas.

In support of the Stipulation, Counsel for Mr. Bobadilla would state to the Court that there is good reason that this condition of release be modified: 1.) the equity amount to secure his appearance would be larger, 2.) Mr. Bobadilla would be able to maintain his employment, 3.) He does not pose a danger to the community, 4.) He is not a flight risk, and 5.) All other terms and conditions of release would remain in full force and effect.

For the above stated reasons Counsel for Mr. Bobadilla would request the Court to Order that property bond condition (7)(1) be modified.

ORDER

IT IS HEREBY ORDERED that Order (7)(1) of the Conditions of Release be modified as follows:

A total equity property bond, of not less than $100,000, secured by property owned by Juventino Ramos Rosas is ordered instead and in place of a total equity property bond of not less than $50,000, secured by property owned by Silvia Hinsunza.

IT IS SO ORDERED.