Robert D. Wilkinson #100478, BAKER MANOCK & JENSEN, PC, Fresno, California, Attorneys for Defendant NGA THIEN NGUYEN.
BENJAMIN WANGER, United States Attorney GRANT B. RABENN, Assistant United States Attorney, Attorneys for Plaintiff United States of America.
CORRECTED STIPULATION AND ORDER FOR RETURN OF DEFENDANT NGA THIEN NGUYEN'S PASSPORT AND PERMISSION TO TRAVEL OUT OF COUNTRY
LAWRENCE J. O'NEILL, District Judge.
WHEREAS the parties hereto, Plaintiff the United States of America and Defendant Nga Thien Nguyen, have entered into a Deferred Prosecution Agreement (Document 89) and have made a motion to the Court that their agreement be approved (Document 90); and
WHEREAS the Court has approved the parties' Deferred Prosecution Agreement (Document 92) and the case as to Defendant Nga Thien Nguyen only has been set for a status conference on the Deferred Prosecution Agreement for January 12, 2015 at 8:30 a.m.; and
WHEREAS defendant Nga Thien Nguyen's father is elderly, lives in Vietnam and there is some doubt that he will survive until the Deferred Prosecution Agreement is fully performed;
The parties hereto, by and through authorized counsel, HEREBY STIPULATE AND AGREE as follows:
1. The Clerk's Office may return to Defendant Nga Thien Nuygen her U.S. Passport, Number XXXXXXXXX, which was surrendered to the Court on or about February 21, 2013. (See Docket entry 26 herein.)
2. The conditions of Defendant Nga Thien Nuygen's pretrial release may be amended to allow her to travel out of the country, with a destination of Vietnam, for the purpose of visiting her father.
Good cause having been shown, IT IS HEREBY ORDERED as follows:
1. Clerk's Office shall return to Defendant Nga Thien Nguyen, either to her personally or through her attorney Robert D. Wilkinson, her U.S. Passport, Number XXXXXXXXX. (See Docket entry 26 herein.)
2. The conditions of Defendant Nga Thien Nguyen's pretrial release shall be modified to allow her to travel outside of the United States, with a destination of ...