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United States v. Young

July 2, 2009

UNITED STATES OF AMERICA, PLAINTIFF,
v.
STEVEN KENNETH YOUNG, DEFENDANT.



The opinion of the court was delivered by: Dennis L. Beck United States Magistrate Judge

EX PARTE REQUEST FOR MODIFICATION OF DEFENDANT'S PRETRIAL RELEASE CONDITIONS; DECLARATION OF COUNSEL; PROPOSED ORDER

Defendant Steven K. Young, through his attorney of record Assistant Federal Defender Victor M. Chavez, hereby requests that this Court modify his pretrial release conditions to enable him to attend a family camping trip from July 3, 2009 to July 5, 2009. His Pretrial Services Officer, Monte Olson is not opposed to this request. Assistant United States Attorney, Sheila K. Oberto is not opposed to this request.

Mr. Young is presently charged with receipt or distribution of child pornography (18 U.S.C. §2252(a)(2)) and possession of same, (18 U.S.C. 2252(a)(4)(B) . He is in compliance with the terms of his pretrial release.

Specifically, Mr. Young, his wife and two children will travel to Tamarack Ridge, just north of Shaver Lake, Fresno County, on July 3, 2009 for a family camping trip. Mr. Young will be with his father Steven Young, Sr., some cousins, and their respective spouses. Mr. Young will be home on July 5, 2009 by 8:00 p.m.

In support of this request, I Victor M. Chavez declare as follows:

1. I am the Assistant Federal Defender appointed to represent Mr. Young in this matter.

2. On June 30, 2009 I spoke with Monte Olson, the Pretrial Services Officer in this case, and he does not oppose Mr. Young's request.

3. On July 1, 2009 Sheila K. Oberto, the Assistant United States in this case stated via email that she does not oppose Mr. Young's request.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. This declaration is made on July 1, 2009 at Fresno, California.

Dated: July 1, 2009

VICTOR M. CHAVEZ

Based on the foregoing, Mr. Young requests that the Court modify his pretrial release conditions as requested and set forth in the proposed order below.

DANIEL J. BRODERICK Respectfully submitted,

Chavez VICTOR M. CHAVEZ Attorney for Defendant ...


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