STIPULATION AND ORDER TO ALLOW DEFENDANT TO TRAVEL TO MEXICO

CAROLYN K. DELANEY, Magistrate Judge.

STIPULATION

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 pretrial services officer, travel to Morelia, Michoacan, Mexico, at any time between February 13, 2019 and February 19, 2019 to visit her father-in-law and brother-in-law, both of whom have been diagnosed with end-stage cancer. The father-in-law is not expected to live longer than about a week from the date this stipulation is filed. Ms. Hermosillo has traveled to Mexico to visit family on 11 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 February 13, 2019. Ms. Hermosillo must return to the United States no later than February 19, 2019 and must check in with and surrender her passport to her pretrial services officer within 24 hours of returning to the United States, but in no event later than February 20, 2019.

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

IT IS SO STIPULATED.

IT IS SO ORDERED.