Opinion
WANGER JONES HELSLEY PC, Oliver W. Wanger, Peter M. Jones, Esq., Fresno, California, Attorneys for: Defendant, JONATHAN CORNELIUS BOURNE
BENJAMIN B. WAGNER, U.S. Attorney, UNITED STATES ATTORNEY'S OFFICE, Laurel Montoya, Assistant U.S. Attorney.
STIPULATION TO VACATE PRETRIAL SUPERVISION CONDITION OF DEFENDNAT'S RELEASE ON HIS PERSONAL RECOGNIZANCE; DECLARATION OF PETER M. JONES IN SUPPORT OF STIPULATION; AND ORDER THEREON
STANLEY A. BOONE, Magistrate Judge.
Defendant, JONATHAN CORNELIUS BOURNE, 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 supervision by Pretrial Services be vacated as a condition of his release on his personal recognizance, and that all other terms and conditions 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, co-counsel of record for Defendant, Jonathan Cornelius Bourne ("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 personal recognizance release was that he would be under the supervision of Pretrial Services. Pretrial Services Officer, Dan Stark notified me that he is recommending that the pretrial supervision condition of Mr. Bourne's release be vacated, and that all other conditions previously imposed remain the same.
4. Officer Stark indicated that he had spoken with AUSA, Laurel Montoya, and that she agrees to stipulate to this change in the conditions of the Defendant's release.
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 November 09, 2015, at Fresno, California.
Respectfully submitted.
ORDER
Having reviewed the above Stipulation and Good Cause Appearing, it is hereby ordered that the condition of pretrial release supervision be vacated from the Defendant's release on his personal recognizance. All other conditions of release shall remain in full force and effect.
IT IS SO ORDERED.