Free Motion to Travel - District Court of California - California

Case 3:08-mj-01821-POR

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Filed 07/24/2008

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STEPHEN P. WHITE Attorney at Law California State Bar No. 125276 101 W. Broadway, Suite 1950 San Diego, California 92101 Telephone: (619) 702-3753 Fax: (619) 238-9914 Attorney for Defendant Darrell Braithwaite

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA
(Honorable Louisa S. Porter) UNITED STATES OF AMERICA, Plaintiff, v. DARRELL BRAITHWAITE, ) ) ) ) ) ) ) ) ) ) ) Criminal Case No. 08-mj-1821 JOINT MOTION TO MODIFY TRAVEL

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COMES NOW the defendant DARRELL BRAITHWAITE, through his counsel, STEPHEN P. WHITE, and the plaintiff, UNITED STATES OF AMERICA, through its counsel, KAREN P. HEWITT, United States Attorney, and GEORGE MANAHAN, Assistant United States Attorney, and jointly move the court that the conditions of Supervised Release previously set for defendant be modified as follows: That the travel restriction for defendant DARRELL BRAITHWAITE be enlarged to permit the defendant to travel to New York beginning on Thursday, July 31, 2008 through Wednesday, August 6, 2008 to visit with his ill father who lives in New York. Defendant Braithwaite will be staying at a relatives home located in New York. ///// /////

Case 3:08-mj-01821-POR

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Filed 07/24/2008

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Mr. Braithwaite has informed the United States Pre-Trial Services officer, Cynthia Ornelas in San Diego and she has no objection to the Request made herein. Defendant is in compliance with all other terms and conditions of his Supervised Release and has not suffered any violations. This stipulation acknowledges that the Assistant United States Attorney has no objection to the modification and enlargement of defendant's travel, as set forth above.

Dated: July 24, 2008

/s/Stephen P. White STEPHEN P. WHITE Attorney for Defendant Darrell Braithwaite

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UNITED STATES OF AMERICA

/s/George Manahan GEORGE MANAHAN Assistant U.S. Attorney

Case 3:08-mj-01821-POR

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Filed 07/24/2008

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CERTIFICATE OF SERVICE

I hereby certify that on July 24, 2008, I electronically filed Defendants Joint Motion to Travel with the Clerk of the Court using the CM/ECF system. I thereby served the opposing party by e-filing to the Office of the Clerk, which will serve the parties listed on the electronic service list for this case.

Respectfully submitted,

/s/Stephen P. White STEPHEN P. WHITE, ESQ. Attorney for Defendant