Filed: Dec. 04, 2019
Latest Update: Dec. 04, 2019
Summary: STIPULATION AND PROPOSED ORDER TO ALLOW DEFENDANT TO TRAVEL LAWRENCE J. O'NEILL , Chief District Judge . TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE LAWRENCE J. O'NEILL AND MICHAEL REDDING, ASSISTANT UNITED STATES ATTORNEY: COMES NOW Defendant, LLAIRS FLORES-LOPEZ, by and through his attorney of record, DAVID A. TORRES hereby requests that he be allowed to travel out of Kern County from December 23, 2019 through January 2, 2020. Mr. Flores-Lopez has informed my office th
Summary: STIPULATION AND PROPOSED ORDER TO ALLOW DEFENDANT TO TRAVEL LAWRENCE J. O'NEILL , Chief District Judge . TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE LAWRENCE J. O'NEILL AND MICHAEL REDDING, ASSISTANT UNITED STATES ATTORNEY: COMES NOW Defendant, LLAIRS FLORES-LOPEZ, by and through his attorney of record, DAVID A. TORRES hereby requests that he be allowed to travel out of Kern County from December 23, 2019 through January 2, 2020. Mr. Flores-Lopez has informed my office tha..
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STIPULATION AND PROPOSED ORDER TO ALLOW DEFENDANT TO TRAVEL
LAWRENCE J. O'NEILL, Chief District Judge.
TO: THE CLERK OF THE UNITED STATES DISTRICT COURT, HONORABLE LAWRENCE J. O'NEILL AND MICHAEL REDDING, ASSISTANT UNITED STATES ATTORNEY:
COMES NOW Defendant, LLAIRS FLORES-LOPEZ, by and through his attorney of record, DAVID A. TORRES hereby requests that he be allowed to travel out of Kern County from December 23, 2019 through January 2, 2020.
Mr. Flores-Lopez has informed my office that he would like to travel to Phoenix, Arizona to spend the holidays with his family. Mr. Flores-Lopez, along with his wife Gabriella (who has been appointed as his third party custodian), and three sons; Rafael (age 17), Daniel (age 11) and Llairs (age 2) will be traveling via automobile to Phoenix, AZ. Mr. Flores-Lopez would like to visit his mother, brother and sister-in-law, who all live in the same residence where Mr. Flores-Lopez and his family will be staying. The defendant intends on leaving at approximately 3:00 a.m. and anticipates driving directly to his mother's residence, which is located at 5748 West Holly Street, Phoenix, Arizona.
Mr. Flores-Lopez was released to a third-party custodian, Gabriela Ramirez Lopez and has been in compliance with all the terms of his supervised release. He is scheduled for a status conference hearing on March 2, 2020.
I have spoken to AUSA Michael Redding and he has no objection to allowing the defendant to travel to Phoenix, Arizona. The court should note that Mr. Flores-Lopez will be away from his residence and off the monitor. Moreover, Pre-Trial Services officer Anthony Perez has been notified of Mr. Flores-Lopez' intent to file this request.
IT IS SO STIPULATED.
Respectfully Submitted,
DATED: December 4, 2019 /s/ David A Torres
DAVID A. TORRES
Attorney for Defendant
LLAIRS FLORES-LOPEZ
DATED: December 4, 2019 /s/ Michael Redding
MICHAEL REDDING
Assistant U.S. Attorney
ORDER
The defendant is allowed to travel to Phoenix, Arizona from December 23, 2019 through January 2, 2020, and contact Pretrial the first court day he returns.
IT IS SO ORDERED.