UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
August 27, 2009
UNITED STATES OF AMERICA, PLAINTIFF,
WILLIAM ERIC BERRY, DEFENDANT.
The opinion of the court was delivered by: Hon. Edward M. Chen U.S. Magistrate Judge
STIPULATION TO AMEND CONDITIONS OF RELEASE TO ENLARGE AREA OF BUSINESS TRAVEL AND RE CURFEW AND [PROPOSED] ORDER
Comes now defendant, WILLIAM ERIC BERRY, by and through his counsel, Frank Bell, and Asst. United States Attorney Kyle Waldinger, and files this Stipulation to Amend the Conditions of Release.
Whereas, at the present time Defendant's travels are confined to the Northern District of California;
Whereas, since his return to his employment Defendant anticipates business travel to as far South as Santa Maria on the Coast and Visalia in the Central Valley, as far North as Redding and as far East as Truckee and Lake Tahoe.
Whereas, on some occasions, such as an upcoming trip to Concord for an evening business meeting, the meeting could run as late as 8:00 p.m, which would make his return to home by 9:00 p.m. difficult if not impossible.
Whereas, Anthony Granados (408) 535-5223, Defendant's Pretrial Services Officer, does not object to a modification of defendant's conditions to permit said travel for business purposes or the change in the curfew and he suggested the language in this stipulation.
IT IS HEREBY STIPULATED THAT, with prior permission of Pretrial Services for each individual occasion, Defendant's business travel be enlarged to the entire State of California and that Defendant may get home at a time past his 9:00 pm curfew.
Dated: August 25, 2009
FRANK BELL Attorney for Defendant WILLIAM ERIC BERRY
KYLE WALDINGER Asst. U.S. Attorney
Good Cause appearing; IT IS SO ORDERED.
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