Opinion
2:12-cr-00187-KJD-PAL
06-14-2013
UNITED STATES OF AMERICA, Plaintiff, v. TRAVIUNTA WOODS, Defendant.
RENE L. VALLADARES Federal Public Defender State Bar No. 11479 MONIQUE KIRTLEY Assistant Federal Public Defender Attorneys for Traviunta Woods RACHEL KORENBLAT Assistant Federal Public Defender
RENE L. VALLADARES
Federal Public Defender
State Bar No. 11479
MONIQUE KIRTLEY
Assistant Federal Public Defender
Attorneys for Traviunta Woods
UNOPPOSED EXPEDITED MOTION
TO TEMPORARILY MODIFY
CONDITIONS OF PRETRIAL RELEASE
TO ALLOW TRAVEL
CERTIFICATION: This Motion is timely filed.
COMES NOW, the Defendant Traviunta Woods, by and through his attorney of record, Rachel Korenblat, Assistant Federal Public Defender, and hereby moves pursuant to 18 U.S.C. § 3145(a)(2) to temporarily modify his conditions of pretrial release to allow Mr. Woods to take his son to Disneyland in Anaheim, California next weekend, the weekend of June 21st. This motion is based on all prior proceedings had herein and the attached memorandum of points and authorities.
RENE L. VALLADARES
Federal Public Defender
By: ____________________
RACHEL KORENBLAT
Assistant Federal Public Defender
FACTS
On May 11, 2012, the Magistrate Court released Traviunta Woods on a Personal Recognizance Bond with Pretrial Release Conditions, which included the conditions that he submit to location monitoring and that he remain in Clark County, Nevada. (CR # 4 at p.2.) Thus, for over a year, Mr. Woods has been monitored by Pretrial Services in the form of Passive Global Position Satellite ("GPS") within Clark County.
Mr. Wood's Pretrial Services Officer, Justin Mounts, has informed the undersigned that Mr. Woods has been compliant with this location monitoring and all other aspects of his Pretrial Release. Mr. Woods, a single father, wishes to take his son to Disneyland in Anaheim, California for the weekend. Mr. Woods would drive from Las Vegas to Disneyland on Friday, June 21st and he would return to Las Vegas by Sunday evening, June 23rd. Mr. Mounts and AUSA Phillip Smith do not oppose this request. Mr. Woods is not requesting modification of any other release conditions.
CONCLUSION
For the aforementioned reasons, Mr. Woods respectfully requests that this Court grant this motion to allow him to travel to Anaheim, California to take his son to Disneyland.
RENE L. VALLADARES
Federal Public Defender
By: ____________________
RACHEL KORENBLAT
Assistant Federal Public Defender
Counsel for Defendant Woods
IT IS SO ORDERED.
____________________
UNITED STATES MAGISTRATE JUDGE
CERTIFICATE OF ELECTRONIC SERVICE
The undersigned hereby certifies that she is an employee of the Law Offices of the Federal Public Defender for the District of Nevada and is a person of such age and discretion as to be competent to serve papers.
That on June 14, 2013, she served an electronic copy of the above and foregoing UNOPPOSED EXPEDITED MOTION TO TEMPORARILY MODIFY CONDITIONS OF PRETRIAL RELEASE TO ALLOW TRAVEL, by electronic service (ECF) to the person named below:
DANIEL G. BOGDEN
United States Attorney
PHILLIP SMITH
Assistant United States Attorney
333 Las Vegas Blvd. So., 5th Floor
Las Vegas, Nevada 89101
Karen Brokaw
Employee of the Federal Public Defender