Free Motion for Bond - District Court of California - California

Case 3:07-cr-03106-BEN

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Filed 06/27/2008

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1 LEILA W. MORGAN

California State Bar No. 232874
2 FEDERAL DEFENDERS OF SAN DIEGO, INC. 225 Broadway, Suite 900 3 San Diego, California 92101-5008 Telephone: (619) 234-8467 Ext. 3737 4 Facsimile: (619) 687-2666 [email protected] 5 6 Attorneys for Ms. Vasquez 7 8 9 10 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HONORABLE ROGER T. BENITEZ) ) ) ) ) ) ) ) ) ) ) ) Case No. 07CR3106-BEN

11 UNITED STATES OF AMERICA, 12 13 v. 14 MARIA VASQUEZ, 15 Defendant. 16 17 TO: 18 19 Plaintiff,

JOINT MOTION TO MODIFY THE CONDITIONS OF BOND

KAREN HEWITT, UNITED STATES ATTORNEY; MICHELLE PETIT, ASSISTANT UNITED STATES ATTORNEY. Maria Vasquez, by and through her attorneys, Leila W. Morgan and Federal Defenders of San Diego,

20 counsel for Ms. Vasquez jointly moves with Assistant United States Attorney Michele Petit, that the 21 conditions of bond set by Magistrate Judge Louisa S. Porter on November 1, 2007, be modified to allow her 22 to travel to Mexico from June 27, 2008 until July 13, 2008, to complete family business affairs. Ms. Vasquez 23 has provided to her supervising pretrial services officer her travel itinerary. Pretrial services has no objection 24 to this modification. 25 Further, the parties request that the Court order Ms. Vasquez to contact her pretrial services officer 26 by telephone once every three days during her trip, and to report to pretrial services in person within twenty27 four hours of her return from Mexico. 28

Case 3:07-cr-03106-BEN

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The surety in this case, Ms. Vasquez's brother, is aware of this condition and consents to the

2 modification, in fact purchasing the airline tickets for the trip himself. // 3 For the foregoing reasons, the parties jointly request that the bond in this case be modified to allow

4 Ms. Vasquez to travel to Mexico from June 27, 2008, until July 13, 2008, with the additional conditions that 5 she report by telephone to pretrial services every three days while she is traveling and report in person to 6 pretrial services within 24 hours of her return from Mexico. 7 Dated: June 27, 2008 8 9 10 Dated: June 27, 2008 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 07cr3106-BEN /s/ Michelle Petit MICHELLE PETIT Assistant United States Attorney [email protected] /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]

Case 3:07-cr-03106-BEN

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing pleading is true and accurate to the best of her

3 information and belief, and that a copy of the foregoing document has been served this day upon: 4 Michelle Petit U S Attorneys Office Southern District of California 5 Civil Division 880 Front Street 6 Suite 6253 San Diego, CA 92101 7 (619)557-5662 Fax: (619)235-2757 8 Email: [email protected] 9 10 Dated: June 27, 2008 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 07cr3106-BEN /s/ Leila W. Morgan LEILA W. MORGAN. Federal Defenders of San Diego, Inc. Attorneys for Ms. Vasquez [email protected]