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United States of America v. Ruben Rodriguez

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA


December 20, 2012

UNITED STATES OF AMERICA,
PLAINTIFF,
v.
RUBEN RODRIGUEZ, DEFENDANTS.

BRUCE LOCKE (#177787) Moss & Locke 800 Howe Avenue, Suite 110 Sacramento, CA 95825 (916) 569-0667 (916) 569-0665 fax Attorneys for RUBEN RODRIGUEZ

STIPULATION AND PROPOSED ORDER TO ALLOW RUBEN RODRIGUEZ TO TRAVEL TO MEXICO FOR THE BIRTH OF HIS FIRST CHILD

IT IS HEREBY STIPULATED AND AGREED between the defendant Ruben Rodriguez, by and through his undersigned defense counsel, and the United States of America by and through its counsel, Assistant U.S. Attorney Lee Bickley, that Mr. Rodriguez may, with the permission of his Pre-Trial Services Officer, and pursuant to such conditions as required by the Pre-Trial Services Officer, travel to Mexico at any time between January 1, 2013 and March 31, 2013 for the purpose of being present at the birth of his first child. It is further stipulated that Mr. Rodriguez must check-in with his Pre-Trial Services Officer as required by the Pre-Trial Services Officer. The Pre-Trial Services Officer may return Mr. Rodriguez's passport to him any time after December 31, 2012 and Mr. Rodriguez must return to the United States by March 31, 2013 and must check in with, and surrender his passport to, his Pre-Trial Services Officer that day.

IT IS SO ORDERED.

20121220

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