Opinion
No. CR-08-0237-EMC
11-04-2011
UNITED STATES OF AMERICA, Plaintiff, v. DAVID NOSAL, Defendant.
STEVEN F. GRUEL Attorney for David Nosal KYLE WALDINGER Assistant United States Attorney
STEVEN F. GRUEL (CSBN 213148)
Attorney at Law
Attorney for David Nosal
STIPULATION AND [PROPOSED] ORDER PERMITING MODIFICATION OF
PRETRIAL CONDITIONS OF RELEASE TO PERMIT TRAVEL TO EUROPE
Defendant David Nosal, by and through his attorney, Steven F. Gruel, hereby requests that his conditions of pretrial release be modified to permit travel to and from Europe on the following dates: Germany and Switzerland from November 7, 2011 to November 15, 2011. This travel is business related.
On April 25, 2008, the Court authorized Mr. Nosal's pretrial release with the standard conditions including a $50,000 unsecured bond, no travel restrictions within the United States and that Mr. Nosal's passport be surrendered to his counsel. Defense counsel informed the Court that Mr. Nosal's employment requires international travel. The Court ordered that any request for international travel required notice to the government and the Court's authorization.
The government does not oppose and stipulates to this defense request. Further, Paul Mameril of Pretrial Services has been contacted and does not object to this defense request. Upon his return to the United States, Mr. Nosal is to surrender his passport to his attorney for safekeeping until further order of the Court. SO STIPULATED:
STEVEN F. GRUEL
Attorney for David Nosal
KYLE WALDINGER
Assistant United States Attorney
[PROPOSED] ORDER
PREDICATED on the above stipulation and GOOD CAUSE APPEARING, defendant David Nosal's pretrial release conditions are modified to allow travel to Europe as stated in the above stipulation
Upon his return to the United States, Mr. Nosal is to surrender his passport to his attorney for safekeeping until further order of the Court. All other conditions of Mr. Nosal's pretrial release shall remain in effect. IT IS SO ORDERED.
Judge Joseph C. Spero