MICHAEL CHASTAINE, State Bar #121209, THE CHASTAINE LAW OFFICE, Gold River, CA, Attorneys for Defendant, Eleazar Nunez.
STIPULATION AND ORDER AUTHORIZING TRAVEL OUTSIDE EASTERN DISTRICT OF CALIFORNIA
EDMUND F. BRENNAN, Magistrate Judge.
On October 22, 2013, Eleazar Nunez plead guilty to a superseding information alleging a violation of 21 USC 841 (distribution of methamphetamine). The terms of the plea agreement prohibit the government from recommending a sentence of more than 70 months.
Mr. Nunez has been out of custody on pre-trial release conditions since November 21, 2013. Among those conditions are condition 5 "travel is restricted to the Eastern District of California", condition 11 "Curfew: You are restricted to your residence every day as directed by the pretrial services officer;" and condition 12 which requires Mr. Nunez to have a home monitoring unit on his person at all times. Mr. Nunez is currently scheduled to be sentenced on February 4, 2014, however, the parties may request to have that date moved.
Mr. Nunez wishes to get married before his sentencing. His family has planned a wedding and short honeymoon in Reno, Nevada. Mr. Nunez has had discussions with his pre-trial officer - Tai Gaskins - regarding this request. Ms. Gaskins has no objection to Mr. Nunez traveling to Reno Nevada on January 25 and returning not later than midnight on Sunday, January 26, 2014. Counsel for Mr. Nunez has spoken to the AUSA in charge of the case - Jill Thomas - and she has indicated that she has no objection to this request.
Therefore, Plaintiff, United States, and Defendant, Eleazar Nunez, through his undersigned counsel, hereby stipulate and agree that the Court should authorize Mr. Nunez to travel outside the Eastern District of California to wit: to Reno, Nevada on January 25, 2014 and return no later than midnight January 26, 2014.
IT IS SO STIPULATED.
IT IS SO ORDERED. Good Cause Appearing, it is hereby ordered that Mr. Nunez is authorized to travel outside the Eastern District of California to wit: to Reno, Nevada on January 25, 2014 ...