STIPULATION TO MODIFY CONDITIONS OF RELEASE

CARL W. HOFFMAN, Magistrate Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Daniel G. Bogden, United States Attorney, and Robert Knief, Assistant United States Attorney, counsel for the United States of America, and Heidi A. Ojeda, Assistant Federal Public Defender, counsel for Toniquewa Ballard, that the employment condition of Ms. Ballard's pre-trial release be modified to allow her the option of participating in educational programs in lieu of seeking employment.

This Stipulation is entered into for the following reasons:

1. On August 3, 2015, the Court released Ms. Ballard on a personal recognizance bond. (See Minutes of Proceedings (#20).) Among the conditions imposed, the Court ordered that the Defendant shall maintain or seek employment. (See PR Bond at 3-4 (#21).)

2. On August 25, 2015, Ms. Ballard's Pretrial Services officer contacted undersigned counsel, alerting undersigned counsel that Ms. Ballard has not yet obtained her general equivalency diploma (GED). Pretrial Services suggested that the parties request that Ms. Ballard's employment condition be modified to include the clause "and/or participate in an educational program." Modification of this condition to include the above language will allow Ms. Ballard to obtain her GED and pursue other educational programs with the time that she would otherwise be required to devote to finding employment.

3. The parties and Pretrial Services believe that allowing Ms. Ballard to obtain her GED and further her education in lieu of seeking employment will assist Ms. Ballard with finding employment at a future date as most companies require a GED.

ORDER

IT IS THEREFORE ORDERED, that Ms. Ballard's employment condition shall be modified to the following: The defendant shall maintain or actively seek lawful and verifiable employment and/or participate in an educational program, and shall notify Pretrial Services or the supervising officer prior to any change.