STIPULATION TO MODIFY PRETRIAL SERVICE RELEASE CONDITIONS; DECLARATION OF PETER M. JONES; AND ORDER THEREON

BARBARA A. MCAULIFFE, District Judge.

TO THE HONORABLE LAWRENCE J. O'NEILL, JUDGE FOR THE UNITED STATES DISTRICT COURT OF THE EASTERN DISTRICT OF CALIFORNIA:

Defendant, PERLA RAMOS, by and through counsel, Peter M. Jones, requests the Court to order the following modification to her pretrial release conditions:

"You must participate in a program of medical or psychiatric treatment, including treatment for drug or alcohol dependency, as approved by your Pretrial Services Officer. You must pay all or part of the costs of the counseling services based on your ability to pay, as determined by your Pretrial Services Officer."

This added condition is being stipulated to by the following:

DECLARATION OF PETER M. JONES

1. I am an attorney duly licensed to practice in the State of California.

2. I am counsel of record for Defendant, Perla Ramos, ("Defendant"), in the above-captioned action. Except as to matters based on information and belief, I have personal knowledge of the matters set forth in this Declaration. Regarding matters stated on information and belief, I believe them to be true. If called upon as a witness to testify about the content of this Declaration, I could and would competently do so.

3. It has come to my attention that Ms. Ramos recently expressed an interest in mental health counseling in light of the substantial emotional distress she is presently experiencing.

4. Assistant U.S. Attorney, Stephanie Stockman, notified me via email that she would agree to stipulate to the above condition being added to Ms. Ramos' pretrial release conditions. 5. U.S. Pretrial Services Officer Jessica McConville contacted me recommending the above condition be added to Ms. Ramos' conditions of release, and indicated she would stipulate to such an addition.

6. It is my information and belief that Ms. Ramos has continuously complied with all the terms and conditions of her pretrial release.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct, and that this Declaration was executed on January 24, 2020, at Fresno, California.

ORDER

Having reviewed the above request and stipulation, good cause appearing, it is hereby ordered that the conditions of Defendant's pretrial release supervision be modified to add the following condition: "You must participate in a program of medical or psychiatric treatment, including treatment for drug or alcohol dependency, as approved by your Pretrial Services Officer. You must pay all or part of the costs of the counseling services based upon your ability to pay, as determined by your Pretrial Services Officer." All other terms and conditions of her pretrial release shall remain in full force and effect.

IT IS SO ORDERED.