UNOPPOSED MOTION TO MODIFY CONDITIONS TO PERMIT TRAVEL (Expedited Treatment Requested

GEORGE FOLEY, Jr., Magistrate Judge.

Comes now the defendant, Johnny Moore, by and through his counsel of record, Raquel Lazo, Assistant Federal Public Defender, and hereby files this Unopposed Motion to Modify Conditions to Permit Travel. This request is based on the Points and Authorities attached hereto.

POINTS AND AUTHORITIES

1) On April 8, 2016, Mr. Moore petitioned this court to modify his conditions to permit him to travel to Fresno, California in order to resolve outstanding traffic warrants. Motion (#74). At a hearing on the matter, the government opposed the motion. After hearing argument on the motion, this court expressed concerns and wanted more information regarding Mr. Moore's proposed travel plans. The court denied the motion without prejudice. See Minutes (#76).

2) Since the hearing, defense counsel has been able to confirm that the Fresno court matter actually involves a pending traffic case. The case is not in warrant status as defense counsel mistakenly represented during the hearing. Defense counsel has provided government counsel with documentation to confirm that the case does exist and is in fact pending. As previously represented, resolution of the traffic case in person will speed up the resolution time because Mr. Moore will be eligible to apply for amnesty. Mr. Moore's fines will also be significantly reduced if he appears in person to resolve. It is important that Mr. Moore be permitted to resolve the citations sooner than later because once he does he will be able to get his license and no longer have to depend on family for transportation to and from work.

3) Mr. Moore has proposed his travel plans to both the government and pretrial services. The trip will be limited to two days and will include an overnight stay in Selma, California.1 Mr. Moore will coordinate with Pretrial Services Officer Lara to arrange the exact travel dates and itinerary should this court grant Mr. Moore's motion. Officer Lara will fashion whatever parameters he feels are necessary for the trip. The parties, however, agree that during the trip Mr. Moore will be limited to the courthouse, hotel, and gas and food establishments along the highway. Mr. Moore will be accompanied by his daughter. His daughter will drive to and from Fresno. Pretrial Services Officer Lara approves of Mr. Moore's daughter as a driver for this trip.

4) Mr. Moore has been fully compliant since being released under pretrial services supervision.

5) Neither the government nor Mr. Moore's Pretrial Services Officer have any opposition to this request.

PROPOSED ORDER

IT IS HEREBY ORDERED that Defendant Johnny Moore, is permitted to travel to Fresno, California to resolve his pending traffic court obligation as deemed appropriate by pretrial services and in accord with the proposals set forth in his Unopposed Motion.