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

Case 3:07-cr-02918-H

Document 35

Filed 12/13/2007

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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 IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (THE HONORABLE MARILYN L. HUFF) UNITED STATES GOVERNMENT, ) Case No. 07CR-2918-H ) Plaintiff, ) ) JOINT MOTION MODIFYING vs. ) DEFENDANT'S CONDITION ALEJANDRO LOPEZ, ) OF RELEASE ) Defendant, ) ) ) COMES NOW the parties, Yesmin E. Saide, Assistant United States Attorney, and Ezekiel E. Cortez, counsel for defendant, Alejandro Lopez respectfully requesting that the travel condition restricting travel to Southern District of California and District of Arizona be modified to allow the defendant to travel throughout the State of California and Nevada from December 23, 2007 to January 7, 2008. Luis Martinez of Pretrial Services has been contacted and has no opposition to the travel modification. The defendant has been instructed to report to Pretrial Services prior to his departure and upon return from his trip. Dated: 12/13/07 /S/ Signature on File by consent YESMIN E. SAIDE Assistant United States Attorney /S/ Ezekiel E. Cortez
EZEKIEL E. CORTEZ Attorney for Alejandro Lopez

Dated: 12/13/07

Joint Motion Modifying Defendant's Conditions of Release, U.S. v .Lopez, 07CR2918-H

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Case 3:07-cr-02918-H

Document 35

Filed 12/13/2007

Page 2 of 2

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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 Defendant: Alejandro Lopez

THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF CALIFORNIA (THE HONORABLE MARILYN L. HUFF) UNITED STATES GOVERNMENT, Plaintiff, vs. ALEJANDRO LOPEZ, Defendant. ) Case No. 07CR-2918-MLH ) ) DEFENDANT'S PROOF OF SERVICE ) ) ) ) ) ) )

I, the undersigned, hereby declare as follows: 1. I am over 18 years of age, a resident of the County of San Diego, State of California, counsel for the Defendant and that my address is 1010 Second Avenue, Suite 1850, San Diego, CA 92101; 2. That today I served the Joint Motion Modifying Defendant's Conditions of Release on opposing counsel by causing to be delivered by e-filing to the Office of the Clerk; and that I mailed a copy to Defendant. I declare under penalty of perjury that the foregoing is true and correct.

Dated: December 13, 2007

/S/Ezekiel E. Cortez Ezekiel E. Cortez

Joint Motion Modifying Defendant's Conditions of Release, U.S. v .Lopez, 07CR2918-H

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