EMERGENCY STIPULATION TO MODIFY CONDITIONS OF RELEASE

GLORIA M. NAVARRO, Chief District 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 Ms. Ballard's pre-trial release conditions be modified to allow her to return to Las Vegas by September 1, 2015.

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 granted Ms. Ballard's unopposed motion to allow her to travel to California for the purposes of meeting with her local Social Security Disability advocate. The Court's order allowed her to travel to California from August 27-29, 2015.

2. Ms. Ballard arranged with Pre-Trial Services that she would travel to California via bus. Ms. Ballard's mother only had sufficient funds purchased a one-way bus ticket. Ms. Ballard's mother believe that she would be paid on Friday, August 28, 2015, and therefore have money to purchase Ms. Ballard's return ticket for Saturday, August 29, 2015. Ms. Ballard's mother however did not get paid, and therefore was unable to purchase a bus ticket for Ms. Ballard to return on August 29, 2015.

3. Throughout the weekend, Ms. Ballard attempted to contact her pre-trial services officer and undersigned counsel. First thing on the morning of August 31, 2015, Ms. Ballard contacted undersigned counsel and her pre-trial services officer, explaining the situation. Ms. Ballard was very concerned about not being able to follow the Court's orders.

4. Undersigned counsel has spoken with Samira Barlow concerning this matter. Ms. Barlow indicated that Ms. Ballard has been in contact with her concerning her travel difficulties and that she understands Ms. Ballard's situation. Ms. Barlow suggested that undersigned counsel submit this request to continue her stay in California so that Ms. Ballard is not technically in violation of the Court's order.

5. The Government has no objection to this requested extension of time to allow Ms. Ballard time to travel back to Las Vegas, Nevada.

6. Based upon Ms. Ballard's efforts to consistently communicate with undersigned counsel and pre-trial services and her good faith efforts in attempting to comply with all the conditions of the Court's order, the parties request that the Court amend its prior order, and order that Ms. Ballard return to Las Vegas, Nevada by September 1, 2015.1

ORDER

IT IS THEREFORE ORDERED that the pretrial release conditions of the defendant be modified to permit Ms. Ballard to return from California to Las Vegas, Nevada by September 1, 2015.