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
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*Attorney for Defendant James Sean Freeman
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10 U NITED S TATES D ISTRICT C OURT
D ISTRICT OF N EVADA
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United States of America,
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Plaintiff, Case No. 2:26-cr-00107-JAD-NJK
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v. Unopposed Motion for Single-Day
14 Travel to Tijuana for Dental Care
James Sean Freeman,
15
Defendant.
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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.
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Case 2:26-cr-00107-JAD-NJK Document 18
19 Filed 07/28/26
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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
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27
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Case 2:26-cr-00107-JAD-NJK Document 18
19 Filed 07/28/26
07/29/26 Page 3 of 3
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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
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v. Proposed Order
5
James Sean Freeman,
6
Defendant.
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Good cause appearing, Mr. Freeman’s unopposed motion is granted.
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IT IS THEREFORE ORDERED that Mr. Freeman may travel to Tijuana,
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Mexico, on August 14, 2026, for the sole purpose of obtaining dental care from
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Amatista Estetica Dental.
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IT IS FURTHER ORDERED that the government must make Mr. Freeman’s
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passport available to him no later than August 13, 2026.
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IT IS FURTHER ORDERED that Mr. Freeman must return his passport to
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the government no later than August 15, 2026.
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IT IS SO ORDERED.
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DATED this 29th day of July, 2026.
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________
20 UNITED STATES MAGISTRATE JUDGE
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EXHIBIT A
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