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


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Date: March 28, 2008
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State: California
Category: District Court of California
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Case 3:07-cr-03271-WQH

Document 15

Filed 03/28/2008

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ELIZABETH M. BARROS California State Bar Number 227629 2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, California 92101 Telephone: (619) 234-8467, ext. 3701
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Attorneys for Ms. Nelson

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE WILLIAM Q. HAYES) UNITED STATES OF AMERICA, Plaintiff, v. TRACY ANN NELSON, Defendant. ) ) ) ) ) ) ) ) ) ) CASE NO. 07CR3271-WQH JOINT MOTION FOR MODIFICATION OF CONDITIONS OF PRETRIAL RELEASE

IT IS HEREBY AGREED BETWEEN THE PARTIES, Elizabeth M. Barros, and Federal Defenders of San Diego, counsel for Ms. Nelson, along with Assistant United States Attorney Steve Miller, and United States Pretrial Services Officer Boris Ilic, that the conditions of pretrial release for Tracy Ann Nelson be modified to allow her to travel to the Central District of California as long as she obtains the consent of Pretrial Services and provides prior notification to Pretrial Services. IT IS FURTHER AGREED BETWEEN THE PARTIES, Elizabeth M. Barros, and Federal Defenders of San Diego, counsel for Ms. Nelson, along with Assistant United States Attorney Steve Miller, and United States Pretrial Services Officer Boris Ilic, that Ms. Nelson's curfew be modified. /// /// /// ///

Case 3:07-cr-03271-WQH

Document 15

Filed 03/28/2008

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Ms. Nelson is currently subject to a 7:00 p.m. curfew. The parties request that Pretrial Services be granted the discretion to extend her curfew on occasion. Respectfully submitted,

DATED:

March 28, 2008

/s/ Elizabeth M. Barros ELIZABETH M. BARROS Federal Defenders of San Diego, Inc. Attorneys for Ms. Nelson /s/ Steve Miller STEVE MILLER Assistant United States Attorney /s/ Boris Ilic BORIS ILIC United States Pretrial Services

DATED:

March 28, 2008

DATED:

March 28, 2008