UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
June 20, 2012
The opinion of the court was delivered by: Hon. Richard G. Seeborg United States District Court Judge
STIPULATION AND [PROPOSED] ORDER TO MODIFY CONDITIONS OF RELEASE
On June 19, 2012, Defendant Kurt Hovan was sentenced to 5 years of probation with a special condition including 12 months of home confinement, following his guilty 22 plea to one count of mail fraud (18 U.S.C. § 1341). Mr. Hovan is currently under the 23 supervision of the Probation Office.
Mr. Hovan requests that the conditions of release be modified to permit him to travel to visit family on the East Coast of the United States during the period from June 21, 2012 through July 15, 2012. In advance of the sentencing hearing on June 19, 2012, Mr. Hovan had anticipated the prospect of a lengthy period of incarceration. In 28 anticipation of such a sentence, Mr. Hovan had planned this trip back East to see his elderly parents before his date of surrender, particularly his mother who suffers from 2 emphysema and other cardiovascular complications and has recently been hospitalized.
of the following condition: that he provides the Probation Office with a full travel 5 itinerary, including any flight information and the addresses of the family residences 6 where he will be staying in Sturbridge, Massachusetts and Avalon, New Jersey. 7 of home confinement. The parties agree that all of the remaining conditions of Mr. 9
Assistant United States Attorney Doug Sprague has informed us that he does not oppose this request. 12 13 14
The parties agree that Mr. Hovan should be permitted to travel upon satisfaction Upon Mr. Hovan's return to California, he is prepared to begin his 12-month term Hovan's original bond shall remain in effect. 10
_June 20, 2012_____ __________________________ DATED Miles Ehrlich 17 Attorney for Kurt Hovan 18 19 _ June 20, 2012_____ __/s/_Doug Sprague __________________ DATED Doug Sprague 20 Assistant United States Attorney
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