HEATHER E. WILLIAMS, Federal Defender.
MATTHEW M. SCOBLE, Assistant Federal Defender, Attorney for Defendant. STEPHEN WOOD
STIPULATION AND [PROPOSED] ORDER TO MODIFY PRE-TRIAL RELEASE CONDITIONS
ALLISON CLAIRE, Magistrate Judge.
IT IS HEREBY STIPULATED AND AGREED between plaintiff, United States of America, and defendant Stephen Wood, through their respective attorneys, that the release conditions imposed on Mr. Wood on April 9, 2013, may be modified as set forth below.
Since the inception of Mr. Wood's Federal case, he has had only limited contact with his family, pursuant to a Yuba County Family court order, and per the terms of his pre-trial release conditions. In compliance with various court orders, Mr. Wood has not been residing with his wife and minor daughter ["family residence"], rather in a mobile home, as approved by Pre-Trial Services ["permanent residence"]. Mr. Wood has only been able to have supervised visits with his family (including minor daughter) during the day in the family residence, but must return to his permanent residence at night.
Recently, as a part of the family reunification process supervised by Child Protective Services [CPS], the Yuba County Family Court and CPS have authorized Mr. Wood to spend one (1) night per week in the family residence. This important step in the family reunification process is at odds with the current Federal conditions of supervised release. Pre-Trial Services and the parties have met and conferred and arrived at a mutually agreeable solution.
Accordingly, the parties and Pre-Trial Services agree that the following conditions may be added:
21. You are permitted to spend one (1) night per week in your family residence in Yuba City California, which includes your wife, minor daughter, and in-laws. The specific night spent in your family residence will be arranged and approved in advance by Pre-Trial Services. On this day, you will be treated as having a reverse curfew', i.e.: you will be expected to remain in your permanent residence during the day, and in your family residence during the evening.
22. It is understood that your daughter will be present during your overnight stays in your family residence. You are not to spend any time with your daughter alone and all visitation with your minor daughter must be supervised by your wife, in-laws, or other third-party approved by the pretrial services officer.
23. You shall not associate or have verbal, written, or telephonic or electronic communication with any person who is under the age of 18, except in the presence of another adult who is the parent or legal guardian of the minor. However, you may have contact with your minor daughter, supervised by your wife, in-laws, or other third-party approved by the pretrial services officer.
All other conditions shall remain in force.
The release conditions previously imposed on Mr. Wood are modified to add the following conditions:
21. You are permitted to spend one (1) night per week in your family residence. The specific night spent in your family residence will be arranged and approved in advance by Pre-Trial Services. On this day, you will be treated as having a reverse curfew', i.e.: you will be expected to remain in your ...