Free Motion to Modify Conditions of Release - District Court of California - California

Case 3:08-cr-03015-W

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Filed 08/11/2008

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DONOVAN J. DUNNION Attorney at Law State Bar No. 70713 402 West Broadway, Suite 2700 San Diego, California 92101 (619) 231-8688 Attorney for Defendant ALBERTO GUTIERREZ-HERNANDEZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. ANTHONY J. BATTAGLIA) UNITED STATES OF AMERICA, ) ) ) ) ) ) ) ) ) ) Case No. 08-mj-01617-AJB JOINT REQUEST AND MOTION TO MODIFY CONDITIONS OF BOND Magistrate Judge: Anthony J. Battaglia

11 Plaintiff, 12 13 ALBERTO GUTIERREZ-HERNANDEZ, 14 Defendant. 15 16 17 18 19 20 21 22 23 24 25 26 Dated: August 8, 2008 27 28 Dated: August 8, 2008 v.

Defendant ALBERTO GUTIERREZ-HERNANDEZ, by and through his attorney of record, Donovan J. Dunnion, and the office of the United States Attorney for the Southern District of California by and through Assistant United States Attorney Peter Ko, hereby request and agree that the condition of bond in the above-entitled matter shall be modified to remove the electronic monitoring imposed by the Court on June 17, 2008, including all restrictions relating thereto. All other bond requirements shall remain in full force and effect.

s/Donovan J. Dunnion DONOVAN J. DUNNION Attorney for Defendant ALBERTO GUTIERREZ-HERNANEZ [email protected] s/Peter Ko PETER KO Assistant U.S. Attorney [email protected]

08-mj-01617-AJB

Case 3:08-cr-03015-W

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Filed 08/11/2008

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ORDER ON JOINT REQUEST Good cause having been shown, IT IS ORDERED that the electronic monitoring of the Defendant Alberto GuiterrezHernandez, including all restrictions related thereto, be terminated effective immediately. All other bond requirements shall remain in full force and effect.

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ANTHONY J. BATTAGLIA Magistrate Judge

08-mj-01617-AJB

Case 3:08-cr-03015-W

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Filed 08/11/2008

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CERTIFICATE OF SERVICE Counsel for Defendant certifies that the foregoing: JOINT REQUEST AND MOTION TO MODIFY CONDITIONS OF BOND is true and accurate to the best of his information and belief, and that a copy of the foregoing documents have been served this day upon: MAILING INFORMATION FOR CASE 08-CR03294-BTM 1. Electronic Mail Notice List

The following are those who are currently on the list to receive email notices for this case. PETER KO [email protected]

Date: August 8, 20008

/s/ Donovan Dunnion DONOVAN DUNNION Attorney for Defendant ALBERTO GUTIERREZ-HERNANDEZ 402 West Broadway, Suite 2700 San Diego, CA 92101 Telephone: (619) 231-8688 [email protected]