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

Case 3:08-cr-00286-BTM

Document 43

Filed 05/19/2008

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DONOVAN & DONOVAN Casey Donovan, Esq. 2 California State Bar Number 182442 The Senator Building 3 105 West F. Street San Diego, California 92101 4 Telephone: (619) 696-8989
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Attorney for Defendant Jennifer Jinesta

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA, Plaintiff, v.

JENNIFER JINESTA, (3) Defendant.

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) ) ) ) ) ) ) ) ) ) ) ) )

Case No. 08cr0286-BTM JOINT MOTION AND STIPULATION REGARDING MODIFICATION OF CONDITIONS OF PRETRIAL RELEASE

IT IS HEREBY STIPULATED by and between the Plaintiff, the United States of America, by and through its counsel, Karen P. Hewitt, United States Attorney, and Randy K. Jones, Assistant United States Attorney, and the defendant, Jennifer Jinesta, by and through her attorney, Casey Donovan, Esq., that the following conditions of pretrial release, as set by this court on January 14, 2008, are modified: It was ordered that the defendant's travel during pretrial release shall be confined to the Southern and Central Districts of California. Ms. Jinesta wishes to travel for purposes of employment as a dancer, and also to visit with friends in Las Vegas, Nevada, during the Memorial Day weekend . Thus the parties agree to expand his travel conditions permit Ms. Jinesta to travel from San Diego , California to Las

Case 3:08-cr-00286-BTM

Document 43

Filed 05/19/2008

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Vegas, Nevada on May 22, 2008, an d return from Las Vegas, Nevada, to San Diego, California on May 26, 2008. Kim Hilton, Ms. Jinesta's pre-trial services officer has been informed of her plans and has agreed to the travel with the condition that Ms. Jinesta informs her prior to her leaving and giving notice upon her return. Counsel has spoken to Charles Johnson and Andrea Johnson, the sureties, by telephone and they have agreed to remain the sureties in this case with the full understanding that she may now travel to Las Vegas during the period from May 22 through May 26, 2008 They have given counsel permission to electronically sign their names to this motion. counsel has also attached their signed acknowledgment's of the change in bond conditions to this motion. Counsel has also spoken to the defendant, Jennifer Jinesta, who also acknowledges that her bond has been modified to permit her to travel to and from Las Vegas during the period May 22 through May 26, 2008, and has given permission to electronically sing her name to this motion. Counsel has also spoken to assistant United States Attorney, Randy K. Jones and informed him of counsel's conversations with both Charles and Andrea Johnson, the sureties, and Jennifer Jinesta, the defendant, and agrees to their signatures appearing electronically on this motion. IT IS SO STIPULATED AND AGREED..

Dated

5/16/08

S/ Casey Donovan CASEY DONOVAN Attorney for defendant Jennifer Jinesta S/ Jennifer Jinesta JENNIFER JIESTA Defendant

Dated

5/16/08

Dated
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5/16/08

S/ Charles Johnson CHARLES JOHNSON Surety

Dated

5/16/08

S/ Andrea Johnson ANDREA JOHNSON Surety

Dated:
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5/16/08

S/ __Randy K. Jones___________________________ RANDY K. JONES Assistant United States Attorney

Case 3:08-cr-00286-BTM

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Filed 05/19/2008

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DONOVAN & DONOVAN Casey Donovan Attorney at Law The Senator Building 105 West F. Street - 4th floor San Diego, CA 92101

U.S.D.C. No.08-CR-0286-BTM

DECLARATION OF SERVICE
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I, undersigned, say: I am over 18 years of age, employed in the County of San
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Diego, California, in which county the within mentioned delivery occurred, and not a party
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to the subject cause. My business address is 105 West F. Street, San Diego, California. I
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served the Defendant's Joint Motion and Stipulation to modify conditions of bond to permit
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travel, along with the singed acknowledgment of both sureties, of which a true and correct
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copy of the documents filed in this cause is affixed, by electronic filing to:
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Randy K. Jones, Assistant U.S. Attorney Office of the United States Attorney 880 Front Street, Room 6293 San Diego, CA 92188 The electronic filing was done by me at San Diego, California, on May 19, 2008. I declare under penalty of perjury that the foregoing is true and correct. Executed on May 19, 2008 at San Diego, California. s/ Casey Donovan

Casey Donovan