STIPULATION AND ORDER TO PERMIT TRAVEL OUTSIDE DISTRICT OF NEVADA

JAMES C. MAHAN, District Judge.

IT IS HEREBY STIPULATED AND AGREED, by and between Eric C. Schmale and Thomas W. Flynn, Trial Attorneys, Tax Division, counsel for the United States of America, and Defendant Chanh Trinh, and his counsel Shawn Perez, that Mr. Trinh be allowed to travel outside the District of Nevada to Southern California to spend the holidays with his wife, family members and his minor children.

Specifically, the parties stipulate and agree that Mr. Trinh shall be permitted to travel from Las Vegas to Southern California on December 23, 2018 through his return on January 5, 2019. Mr. Trinh will be taking his children, ages 5 and 7, and his wife to visit relatives and tour several sites in Southern California. Upon his return he shall report his arrival to his pretrial officer.

Counsel for Defendant attempted to contact Mr. Trinh's pretrial officer and left a message in order to seek approval. As of the date of this stipulation, counsel has not received a return call. Because of holiday schedules this stipulation is being filed in order to assure that the Trinh family will be able to plan for the holiday week.

ORDER

UPON GOOD CAUSE HAVING BEEN SHOWN, IT IS HEREBY ORDERED that Defendant Chanh Trinh be permitted to travel from Las Vegas, Nevada to Southern California in order to spend time with his children and family for the holidays, from the morning of December 23, 2018, until his return on the evening of January 5, 2019. Upon his return he shall report his arrival to his pretrial officer.

All other current conditions of Defendant's pre-trial release shall remain in place.

IT IS SO ORDERED.