Opinion
Case No.: 1:12CR0341 LJO-SKO
02-12-2013
UNITED STATES OF AMERICA, Plaintiff(s), v. PAUL NOKHAM Defendant.
PETER M. JONES, Attorney for Defendant, PAUL NOKHAM BENJAMIN B. WAGNER, U.S. Attorney UNITED STATES ATTORNEY'S OFFICE KAREN A. ESCOBAR, Assistant U.S. Attorney
WANGER JONES HELSLEY PC
265 E. River Park Circle, Suite 310
Post Office Box 28340
Fresno, California 93729
Telephone: (559) 233-4800
Facsimile: (559) 233-9330
Peter M. Jones, Esq. SBN# 105811 Attorneys for: Defendant, PAUL NOKHAM
STIPULATION TO VACATE
PRETRIAL RELEASE CONDITION;
DECLARATION OF PETER M.
JONES IN SUPPORT OF
STIPULATION; AND ORDER
THEREON
Defendant, PAUL NOKHAM, by and through counsel, Peter M. Jones, and Plaintiff, UNITED STATES OF AMERICA, by and through counsel, Benjamin B. Wagner hereby stipulate as follows:
That the condition of pretrial release that the Defendant reside with a third party custodian be vacated. All other terms and conditions of pretrial release are to remain in full force and effect.
DECLARATION OF PETER M. JONES
1. I am an attorney duly licensed to practice in the State of California.
2. I am with the law firm of Wanger Jones Helsley PC, counsel of record for Defendant, PAUL NOKHAM ("Defendant") in the above-captioned action. Except as to matters based on information and belief, I have personal knowledge of the matters set forth in this Declaration. Regarding matters stated on information and belief, I believe them to be true. If called upon as a witness to testify about the content of this Declaration, I could and would competently do so.
3. One of the conditions of Defendant's pretrial release was that he reside with a third party custodian. I have discussed this condition with Pretrial Services Officer, Dan Starks. Officer Starks has no opposition to the Third Party Custodian condition of the Defendant's release being vacated.
I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct, and that this Declaration was executed on February 11, 2013, at Fresno, California.
________
Peter M. Jones
Respectfully submitted,
By: ________
PETER M. JONES, Attorney for
Defendant, PAUL NOKHAM
BENJAMIN B. WAGNER, U.S. Attorney
UNITED STATES ATTORNEY'S OFFICE
By:________
KAREN A. ESCOBAR,
Assistant U.S. Attorney
ORDER
Having reviewed the above Stipulation and Good Cause Appearing, it is hereby ordered that the condition of pretrial release requiring Defendant, Paul Nokham to reside with a third party custodian be vacated. All other conditions of release shall remain in full force and effect. IT IS SO ORDERED.
Sheila K. Oberto
UNITED STATES MAGISTRATE JUDGE