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


File Size: 34.5 kB
Pages: 3
Date: September 4, 2008
File Format: PDF
State: California
Category: District Court of California
Author: unknown
Word Count: 347 Words, 2,091 Characters
Page Size: Letter (8 1/2" x 11")
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Case 3:08-cr-01971-W

Document 34

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DAVID BAKER 419 19TH ST San Diego, CA 92102 (619)743-0121 Attorney for, GARCIA-RODRIGUEZ

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA (HON. THOMAS J. WHELAN) UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) vs. ) ) FRANCISCO GARCIA-RODRIGUEZ, ) ) Defendant. ) ________________________________________ ) Case No. 08-CR-1971-W DECLARATION OF DAVID BAKER AND REQUEST TO MODIFY BOND CONDITIONS AND STIPULATION OF PARTIES Date:SEPT 4,2008 Time:

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I am Attorney of Record in the above entitled case for Defendant Francisco Garcia. One of 18 the conditions for Mr. Garcia's pre-trial release allows Mr. Garcia to travel to Mexico two days per 19 week for work. The court made it a requirement for Mr. Garcia to leave two car titles with the court 20 as a condition of Francisco's travel to Mexico. The condition was added to the bond by modification 21 in front of Judge Papas on June 16, 2008. Mr. Garcia is in the business of selling vehicles and he is 22 hoping to sell the vehicles the court is holding title to. I have spoken at length with Pre Trial officer 23 Eleonor Ruiz and Assistant U.S. Attorney James Melendres about the issue of car titles. We are all 24 in agreement that the condition requiring Mr. Garcia to leave car titles with the court should be lifted. 25 I respectfully request the court to lift the requirement that two car titles be left on file at the clerks 26 office.. 27 28

Case 3:08-cr-01971-W

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 : ____d/Baker__________________ David Baker Attorney for Francisco Garcia ___e/Ruiz_____________________ Eleonor Ruiz Pre-Trial J / Melendres______________ James Melendres Assistant U.S. Attorney So Stipulated: Stipulated to by Defense Counsel, Pre Trial and the U.S. Attorneys office.

Case 3:08-cr-01971-W

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