STIPULATION AND [PROPOSED] ORDER TO MODIFY CONDITIONS OF RELEASE

KANDIS A. WESTMORE, Magistrate Judge.

Defendant Andrew Zahn and the United States hereby stipulate and agree as follows:

1) On May 2, 2018, the Court modified Mr. Zahn's conditions of release as follows: "Defendant allowed to access his mother's computer only if she permits Pretrial Services to install the monitoring software. Defendant allowed to use the computer for banking, getting directions, reading the newspaper and technical support for his mother." Docket 11.

2) The parties have met and conferred regarding the conditions under which Mr. Zahn should be permitted to use the computer beyond the terms of the Court's current order. The parties agree that Mr. Zahn should be permitted broader access to his mother's monitored computer, subject to certain restrictions.

3) Accordingly, the parties agree that the Court should modify the conditions of Mr. Zahn's release to allow Mr. Zahn to access his mother's monitored computer but to prohibit use of video conferencing applications, use of peer-to-peer file sharing applications, and access to materials depicting child pornography, child erotica, or nude or sexual depictions of any child, or any materials described at 18 U.S.C. § 2256(8).

4) The parties additionally request that the curfew imposed as a condition of release be modified to require Mr. Zahn to be in his apartment between 11:00 p.m. and 5:00 a.m. unless otherwise approved by Pretrial Services.

5) The parties have conferred with Pretrial Services Officer Kenneth J. Gibson, who has no objection to these modifications.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Pursuant to stipulation, IT IS SO ORDERED. Mr. Zahn's conditions of release are modified to provide as follows: