Filed: Jun. 05, 2019
Latest Update: Jun. 05, 2019
Summary: EX PARTE APPLICATION FOR AMENDED ORDER TO MODIFY DEFENDANT'S BOND; DECLARATION OF VICTOR SHERMAN;ORDER BARBARA A. McAULIFFE , Magistrate Judge . Defendant, Ruben Cortez-Rocha, by and through his counsel of record, Victor Sherman, hereby applies Ex Parte to this Honorable Court for an Amended Order to modify the conditions of his bond. This motion is based upon the files and records in this case and the attached Declaration of Victor Sherman. Respectfully submitted, /s/Victor Sherman By:
Summary: EX PARTE APPLICATION FOR AMENDED ORDER TO MODIFY DEFENDANT'S BOND; DECLARATION OF VICTOR SHERMAN;ORDER BARBARA A. McAULIFFE , Magistrate Judge . Defendant, Ruben Cortez-Rocha, by and through his counsel of record, Victor Sherman, hereby applies Ex Parte to this Honorable Court for an Amended Order to modify the conditions of his bond. This motion is based upon the files and records in this case and the attached Declaration of Victor Sherman. Respectfully submitted, /s/Victor Sherman By: ..
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EX PARTE APPLICATION FOR AMENDED ORDER TO MODIFY DEFENDANT'S BOND; DECLARATION OF VICTOR SHERMAN;ORDER
BARBARA A. McAULIFFE, Magistrate Judge.
Defendant, Ruben Cortez-Rocha, by and through his counsel of record, Victor Sherman, hereby applies Ex Parte to this Honorable Court for an Amended Order to modify the conditions of his bond.
This motion is based upon the files and records in this case and the attached Declaration of Victor Sherman.
Respectfully submitted,
/s/Victor Sherman
By: ___________________________
VICTOR SHERMAN
Attorney for Defendant
Ruben Cortez-Rocha
DECLARATION OF VICTOR SHERMAN
I, Victor Sherman, declare as follows:
1. I am attorney at law duly licensed to practice before this Honorable Court, and represent the defendant, Ruben Cortez-Rocha, in the above-entitled matter.
2. Currently, the defendant's bond has been modified to a curfew of 7:00 p.m. to 7:00 a.m. for employment purposes and the defendant must notify his supervising officer, Brenda Mercado, of his whereabouts.
3. Since the defendant has not secured new gainful employment, defense counsel would like the defendant's bond to be modified so as to allow his pretrial service officer to adjust his restrictions for medical, religious services, employment, or court ordered obligations, as the officer deems appropriate.
4. Defense counsel has spoken to the Assistant United States Attorney, Angela Scott, who agrees with the above request for modification.
5. Defense counsel has also been in contact with the defendant's pretrial service officers, Brenda Mercado, in the Central District of California, and pretrial service officer, Frank Guerrero, in the Eastern District of California, who indicated that this modification is at their request.
6. Therefore, it is respectfully requested that the Court issue an Order for the defendant's bond to be modified for medical, religious services, employment, or court ordered obligations as the pretrial officer deems appropriate, and will adjust his restrictions. All other conditions of the bond are to remain in full force and effect.
I declare under penalty of perjury that the foregoing is true and correct.
/s/Victor Sherman
_________________
VICTOR SHERMAN
ORDER
GOOD CAUSE APPEARING THEREFOR;
IT IS HEREBY ORDERED that the defendant's bond to be modified so as to allow his pretrial service officer to adjust his restrictions for medical, religious services, employment, or court ordered obligations, as the pretrial officer deems appropriate.
IT IS SO ORDERED.
