Free Motion for Bond - District Court of California - California

Case 3:08-cr-02360-H

Document 24

Filed 09/02/2008

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SHAUN KHOJAYAN (#197690) THE LAW OFFICES OF SHAUN KHOJAYAN & ASSOCIATES, P.L.C. 121 Broadway, Suite 338 San Diego, CA 92101 Telephone: (619) 338-9110 Facsimile: (619) 338-9112 Email: [email protected] Attorney for Defendant Sevilla

6 7 8 9 10 11 12 13 14 15 16 17 18 19 States Attorney, Harold Chun, and defendant, Ernesto Sevilla, by and through his attorney, 20 21 22 23 24 25 26 27 28 modifications and has no objection to Ernesto Sevilla remaining at his specified residence from 1. 08CR2360-H Shaun Khojayan, and jointly move for an order modifying bond conditions. WHEREAS the parties agree to modify bond as follows: (1) That Ernesto Sevilla be permitted to remain at his specified residence from COME NOW plaintiff the United States of America, by and through its Assistant United v. ERNESTO SEVILLA, Defendants. UNITED STATES OF AMERICA, Plaintiff, JOINT MOTION FOR MODIFICATION OF BOND CONDITIONS Case No.: 08CR2360-H UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

12:00 a.m. until 5:00 a.m. daily to facilitate his full time employment; (2) All other bond conditions to remain the same.

WHEREAS the Pre Trial Services officer Cynthia Ornelas has been informed of these

Case 3:08-cr-02360-H

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12:00 a.m. until 5:00 a.m. daily. WHEREAS defense counsel has consulted the surety Ricardo Chacon and he is agreeable to these modifications. WHEREAS defense counsel has consulted the surety Jose Alfredo Garcia, Jr. and he is

5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2. 08CR2360-H Dated: ______________________________________ Jose Alfredo Garcia, Jr. MODIFICATION AGREED TO BY: Dated: ___________________________________ Ricardo Chacon By: s/Harold Chun (with permission) Harold Chun Email: [email protected] Dated: August 27, 2008 Respectfully submitted, ASSISTANT U.S. ATTORNEY Dated: August 27, 2008 LAW OFFICES OF SHAUN KHOJAYAN & ASSOCIATES, P.L.C. By: _ s/Shaun Khojayan______ Shaun Khojayan Email: [email protected] Attorney for Ernesto Sevilla agreeable to these modifications. Therefore, the parties jointly request that Mr. Sevilla's bond be modified to allow him to reside at his specified residence from 12:00 a.m. until 5:00 a.m. Respectfully submitted,

Case 3:08-cr-02360-H

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Case 3:08-cr-02360-H

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate and that a

3 copy of the foregoing document has been served this day upon: 4 Electronic Mail Notice List 5 The following are those who are currently on the list to receive e-mail notices for this case. 6 7 8 9 10 11 Manual Notice List Shaun Khojayan [email protected] [email protected] U S Attorney CR [email protected]

The following is the list of attorneys who are not on the list to receive e-mail notices for this case (who therefore require manual noticing). You may wish to use your mouse to select and copy 12 this list into your word processing program in order to create notices or labels for these recipients. 13 14 15 16 17 Dated: September 2, 2008 18 19 20 21 22 23 24 25 26 27 28 -1­
CERTIFICATE OF SERVICE

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(No manual recipients)

I declare under penalty of perjury that the foregoing is true and correct.

s/ Shaun Khojayan___________ Shaun Khojayan, Declarant