Free Motion to Modify Conditions of Release - District Court of California - California

Case 3:08-cr-00021-DMS

Document 59

Filed 05/23/2008

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Ezekiel E. Cortez CA Bar No. 112808 The Executive Complex 1010 Second Avenue, Suite 1850 San Diego, CA 92101 Tel (619)237-0309 Fax (619)237-8052 Attorney for Olivia Fimbres IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (THE HONORABLE DANA M. SABRAW) UNITED STATES GOVERNMENT, ) Case No. 08CR-0021 ) Plaintiff, ) ) JOINT MOTION MODIFYING vs. ) DEFENDANT'S CONDITION OLIVIA FIMBRES, ) OF RELEASE ) Defendant, ) )
COMES NOW the parties, Christopher Alexander, Assistant United States Attorney, and Ezekiel E. Cortez, counsel for defendant, Olivia Fimbres respectfully requesting that the travel condition restricting travel to Southern District of California be modified to allow the defendant to travel to Los Angeles California, from May 25, 2008 to May 26, 2008. Tammy Riddling of Pretrial Services has been contacted and has no opposition to the travel modification. The defendant has been instructed to provide Pretrial Services with an itinerary of her travel arrangements and to report to Pretrial Services prior to her departure and upon return from her trip to Los Angeles. Dated: May 23,2008 /s/ Christopher Alexander by consent CHRISTOPHER ALEXANDER Assistant United States Attorney /s/ Ezekiel E. Cortez EZEKIEL E. CORTEZ Attorney for defendant Olivia Fimbres

Dated: May 23,2008

Joint Motion Modifying Defendant's Condition Of Release, U.S. v. Fimbres, 08-CR-0021

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