Opinion
No. CR-S-11-CR-296 WBS
03-27-2013
UNITED STATES OF AMERICA, Plaintiff, v. MANUEL HERRERA, Defendant.
JOHN R. MANNING (SBN 220874) ATTORNEY AT LAW Attorney for Defendant MANUEL HERRERA LEE BICKLEY Assistant United States Attorney
JOHN R. MANNING (SBN 220874)
ATTORNEY AT LAW
Attorney for Defendant
MANUEL HERRERA
AMENDED STIPULATION AND
PROPOSED ORDER ALLOWING MANUEL
HERRERA TO TRAVEL TO MEXICO IN
ORDER TO VISIT HIS AILING MOTHER
IT IS HEREBY STIPULATED AND AGREED between defendant Manuel Herrera, by and through his undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Lee Bickley, Mr. Herrera may, with the permission of his Pre-Trial Services Officer, and pursuant to such conditions as required by his Pre-Trial Services Officer, travel to Mexico at any time between April 5, 2013 and April 15, 2013 for the purpose of visiting his sick mother. (Mr. Herrera's mother is recuperating from a cardiac incident.) It is further stipulated Mr. Herrera must check-in with his Pre-Trial Services Officer as required by his Pre-Trial Services Officer. Pre-Trial Services shall return Mr. Herrera's passport to him no later than April 3, 2013. Mr. Herrera must return to the United States by April 15, 2013 and must check in with, and surrender his passport to, his Pre-Trial Services Officer within 24 hours of returning to the United States, but in any event, no later than April 16, 2013.
Mr. Herrera originally asked, and the Court agreed, to travel to Mexico between April 1, 2013 and April 10, 2013. Unfortunately, for scheduling reasons, it is not possible for Mr. Herrera to travel as originally planned (and requested) and he is requesting the Court modify his proposed travel as indicated herein. IT IS SO STIPULATED.
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JOHN R. MANNING
Attorney for Defendant
Manuel Herrera
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LEE BICKLEY
Assistant United States Attorney
IT IS SO ORDERED,
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ALLISON CLAIRE
UNITED STATES MAGISTRATE JUDGE