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Unopposed Motion for Single-Day Travel to Tijuana for Dental Care — United States v. James Sean Freeman

Summary

This is an unopposed motion for single-day travel to Tijuana for dental care in the District of Nevada, Case No. 2:26-cr-00107-JAD-NJK, United States of America against James Sean Freeman. Counsel for Mr. Freeman asks permission to travel to Tijuana, Mexico on August 14, 2026, and asks the Court to order the government to return the passport for a limited period. The motion says pretrial services and the government have no objection and will defer to the Court. The proposed order would require the passport to be available no later than August 13, 2026 and returned no later than August 15, 2026. The motion is dated July 28, 2026 and carries the /s/ signature of Rick Mula.

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Cite this document

“Unopposed Motion for Single-Day Travel to Tijuana for Dental Care — United States v. James Sean Freeman.” Original at archive.org. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/court-filing-no-2-26-cr-00107-dkt-19-28a418ee09/, SHA-256 a2508ec32587eb808ab42b6cd6361b05058d47e422dceb7c8edb0694425f8aa4.

Full text

         Case 2:26-cr-00107-JAD-NJK       Document 19     Filed 07/29/26   Page 1 of 9




1    Rene L. Valladares
     Federal Public Defender
2    Nevada State Bar No. 11479
3    *Rick Mula
     Assistant Federal Public Defender
4    411 E. Bonneville Ave., Ste. 250
     Las Vegas, Nevada 89101
5    (702) 388-6577
6    Rick_Mula@fd.org

7
     *Attorney for Defendant James Sean Freeman
8

9

10                         U NITED S TATES D ISTRICT C OURT
                                 D ISTRICT OF N EVADA
11
     United States of America,
12
                  Plaintiff,                       Case No. 2:26-cr-00107-JAD-NJK
13
           v.                                      Unopposed Motion for Single-Day
14                                                 Travel to Tijuana for Dental Care
     James Sean Freeman,
15
                  Defendant.
16

17                                          Motion
18         Mr. Freeman respectfully requests permission for single-day travel to Tijuana,
19   Mexico for dental care on August 14, 2026. He further requests that the Court order
20   the government to return his passport to him for a limited period of time to facilitate
21   travel. This motion is unopposed.
22

23

24

25

26

27
         Case 2:26-cr-00107-JAD-NJK       Document 18
                                                   19      Filed 07/28/26
                                                                 07/29/26   Page 2 of 3
                                                                                      9




1                                    Points & Authorities
2          The Court may modify conditions of pretrial release pursuant to 18 U.S.C. §
3    3142(c)(3). Specifically, “[t]he judicial officer may at any time amend the order to
4    impose additional or different conditions of release.” Id.
5          Mr. Freeman respectfully requests permission to travel to Tijuana, Mexico for
6    a single day (August 14, 2026) for dental care. Mr. Freeman has received dental care
7    from Amatista Estetica Dental on a prior occasion. (Ex. A (messages regarding Mr.
8    Freeman’s prior appointment in 2025).) Mr. Freeman now has scheduled an
9    appointment for August 14, 2026. (Ex. B (messages confirming upcoming
10   appointment).) He seeks dental care in Tijuana because it is more affordable than
11   dental offices in the United States. If permitted to travel for the appointment, he
12   would travel by car and he would be accompanied by his cousin (a woman
13   approximately 35 years old). Mr. Freeman further requests that the Court order the
14   government to provide him with his passport temporarily to facilitate travel. He
15   would request that the Court order the passport to be made available to him no later
16   than August 13, 2026, and he would return it to the government on August 15, 2026.
17         Defense counsel has conferred with pretrial services and the government.
18   Neither entity has any objection and will defer to the Court.
19         Dated July 28, 2026.
20
                                                     Respectfully submitted,
21

22                                                   Rene L. Valladares
                                                     Federal Public Defender
23

24                                                   /s/ Rick Mula
                                                     Rick Mula
25                                                   Assistant Federal Public Defender
26

27


                                                 2
         Case 2:26-cr-00107-JAD-NJK     Document 18
                                                 19       Filed 07/28/26
                                                                07/29/26   Page 3 of 3
                                                                                     9




1                         U NITED S TATES D ISTRICT C OURT
2                               D ISTRICT OF N EVADA
     United States of America,
3
                 Plaintiff,                         Case No. 2:26-cr-00107-JAD-NJK
4
           v.                                       Proposed Order
5
     James Sean Freeman,
6
                 Defendant.
7

8
           Good cause appearing, Mr. Freeman’s unopposed motion is granted.
9
           IT IS THEREFORE ORDERED that Mr. Freeman may travel to Tijuana,
10
     Mexico, on August 14, 2026, for the sole purpose of obtaining dental care from
11
     Amatista Estetica Dental.
12
           IT IS FURTHER ORDERED that the government must make Mr. Freeman’s
13
     passport available to him no later than August 13, 2026.
14
           IT IS FURTHER ORDERED that Mr. Freeman must return his passport to
15
     the government no later than August 15, 2026.
16
           IT IS SO ORDERED.
17
           DATED this 29th day of July, 2026.
18

19
                                                                        ________
20                                              UNITED STATES MAGISTRATE JUDGE
21

22

23

24

25

26

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                                                3
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-1 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page41ofof94




         EXHIBIT A




         EXHIBIT A
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-1 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page52ofof94
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-1 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page63ofof94
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-1 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page74ofof94
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-2 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page81ofof92




         EXHIBIT B




         EXHIBIT B
Case
 Case2:26-cr-00107-JAD-NJK
      2:26-cr-00107-JAD-NJK Document
                             Document 19
                                     18-2 Filed
                                           Filed07/29/26
                                                 07/28/26 Page
                                                           Page92ofof92


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