Free Motion to Travel - District Court of California - California

Case 3:08-cr-00092-DMS

Document 38

Filed 06/24/2008

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STEPHEN P. WHITE Attorney at Law California State Bar No. 125276 101 W. Broadway, Suite 1950 San Diego, California 92101 Telephone: (619) 702-3753 Fax: (619) 238-9914 Attorney for Defendant Nathaniel Gregory Williams

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
(Honorable Irma E. Gonzalez) ) ) Plaintiff, ) ) v. ) ) NATHANIEL GREGORY WILLIAMS, ) ) Defendant. ) ) UNITED STATES OF AMERICA, Criminal Case No. 08-cr-0092 (IEG) JOINT MOTION TO MODIFY TRAVEL

COMES NOW the defendant NATHANIEL GREGORY WILLIAMS, through his counsel, STEPHEN P. WHITE, and the plaintiff, UNITED STATES OF AMERICA, through its counsel, KAREN P. HEWITT, United States Attorney, and A. DALE BLANKENSHIP, Assistant United States Attorney, and jointly move the court that the conditions of Supervised Release previously set for defendant be modified as follows: That the travel restriction for defendant NATHANIEL GREGORY WILLIAMS be enlarged to permit the defendant to travel to Idyllwild, CA beginning on Friday, June 27, 2008 through Monday, June 30, 2008 for a camping trip with his grandmother and grandfather who both have signed as the surety for Mr. Williams bond. Defendant Williams will be traveling and spending the entire camping trip with his grandparents. ///// /////

Case 3:08-cr-00092-DMS

Document 38

Filed 06/24/2008

Page 2 of 2

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Mr. Williams has informed the United States Pre-Trial Services officer, Dave Horton in San Diego and he has no objection to the Request made herein. Defendant is in compliance with all other terms and conditions of his Supervised Release and has not suffered any violations. This stipulation acknowledges that the Assistant United States Attorney has no objection to the modification and enlargement of defendant's travel, as set forth above.

Dated: June 23, 2008

/s/Stephen P. White STEPHEN P. WHITE Attorney for Defendant Nathaniel Gregory Williams

Dated: June 23, 2008 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

UNITED STATES OF AMERICA

/s/A. Dale Blankenship A. Dale Blankenship Assistant U.S. Attorney