STIPULATION TO MODIFY CONDITIONS OF RELEASE; [PROPOSED] ORDER

EDMUND F. BRENNAN, Magistrate Judge.

The United States of America, by and through its Counsel of Record, William E. Nolan, Special Litigation Counsel for the United States Department of Justice, the Civil Rights Division (the "Government"), and Defendant Firdos Sheikh, M.D. ("Dr. Sheikh" or "Defendant"), by and through her counsel of record, Yasin M. Almadani, (collectively, the "Parties") hereby file this Stipulation to modify Dr. Sheikh's conditions of release.

This Stipulation is based on the following:

1. Dr. Sheikh is on pre-trial release in the above-captioned case;

2. On May 17, 2019, the Parties stipulated to various conditions of release including home detention and location monitoring, which the Court ordered;

3. The Parties and the assigned Pre-Trial Services Officer discussed the opportunity for Dr. Sheikh to have the home detention and location monitoring conditions removed after 90 days of compliance with her modified conditions of release;

4. As of the date of this filing, Dr. Sheikh has been in full compliance with her modified conditions of release for over 90 days;

5. Counsel for Dr. Sheikh has conferred with the assigned Pre-Trial Services Officer who has no objection to the modification requested herein;

6. The Parties thus stipulate that Dr. Sheikh's conditions of release be modified to remove the following conditions:

a. Condition No. 11: You must participate in the following location monitoring program component and abide by all the requirements of the program, which will include having a location monitoring unit installed in your residence and a radio frequency transmitter device attached to your person. You must comply with all instructions for the use and operation of said devices as given to you by the Pretrial Services Agency and employees of the monitoring company. You must pay all or part of the costs of the program based upon your ability to pay, as determined by the pretrial services officer;

b. Condition No. 12: HOME DETENTION: You must remain inside your residence at all times except for employment; education; religious services; medical, substance abuse, or mental health treatment; attorney visits; court appearances; court ordered obligations; or other activities pre-approved by the pretrial services officer.

[PROPOSED] ORDER

UPON STIPULATION OF THE PARTIES and GOOD CAUSE APPEARING THEREIN, IT IS ORDERED that the following conditions of release be removed:

1. Condition No. 11: You must participate in the following location monitoring program component and abide by all the requirements of the program, which will include having a location monitoring unit installed in your residence and a radio frequency transmitter device attached to your person. You must comply with all instructions for the use and operation of said devices as given to you by the Pretrial Services Agency and employees of the monitoring company. You must pay all or part of the costs of the program based upon your ability to pay, as determined by the pretrial services officer;

2. Condition No. 12: HOME DETENTION: You must remain inside your residence at all times except for employment; education; religious services; medical, substance abuse, or mental health treatment; attorney visits; court appearances; court ordered obligations; or other activities pre-approved by the pretrial services officer.

SO ORDERED.