STIPULATION AND [PROPOSED] ORDER TO MODIFY CONDITIONS OF PRETRIAL RELEASE

KANDIS A. WESTMORE, Magistrate Judge.

Shantell Latrice Daniels is currently on pre-trial release, pending resolution or trial in the above-entitled case. As the court is aware, Ms. Daniels is now living in Las Vegas, NV after a period of homelessness in California. Among Ms. Daniels' conditions are that she seek and maintain gainful employment, and that she comply with a curfew which requires her to be in her home between 8:00 pm and 6:00 am.

Ms. Daniels has recently secured employment in the warehouse of a company called World Pack in Las Vegas, NV. The shift for which she was hired runs from 3:00 pm to 11:00pm. This schedule would require a modification of her curfew to 12:00 am to 6:00 am in order to accommodate her work schedule.

Upon the request of Ms. Daniels, by and through her counsel of record, Dena Marie Young, and upon agreement of the United States and Pre-Trial Services, and good cause appearing because defendant needs to work in order to better herself and to comply with her pre-trial release conditions, defendant's curfew shall be modified to 12:00 am to 6:00 am in order to accommodate the hours of her employment .

Defendant shall keep Pretrial Services informed of any changes in her employment schedule.

ALL OTHER TERMS AND CONDITIONS OF PRETRIAL RELEASE ARE TO REMAIN UNCHANGED.

SO STIPULATED.

IT IS SO STIPULATED.

[PROPOSED] ORDER

GOOD CAUSE APPEARING,

Defendant's curfew shall be modified to 12:00 am to 6:00 am in order to accommodate the hours of her employment. Defendant shall keep Pretrial Services informed of any changes in her employment schedule.

ALL OTHER TERMS AND CONDITIONS OF PRETRIAL RELEASE ARE TO REMAIN UNCHANGED.

IT IS SO ORDERED.