Emergency Stipulation to Modify Conditions of Release — United States v. Karen Chapon, No. 2:20-cr-286-JCM-NJK (Dkt. 56, D. Nev.)

Summary

In this emergency stipulation in United States v. Karen Chapon, Case No. 2:20-cr-286-JCM-NJK (D. Nev.), the government and the Federal Public Defender agreed to amend Chapon's pretrial release travel condition to allow travel to the State of Colorado. The stated reason is that Chapon's father is dying of cancer and was recently placed in hospice care. The filing says Chapon had been on pretrial supervision for eight months, with a minor violation being addressed by an agreement to forfeit a medical marijuana card, and that the pretrial services officer had no objection. The plan was to fly to Colorado on Friday, July 9, 2021 and return on July 26, 2021. The filing ends with an "IT IS SO ORDERED" block for U.S. Magistrate Judge Brenda Weksler dated July 9, 2021.

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Full text

Case 2:20-cr-00286-JCM-NJK Document 55 Filed 07/09/21 Page 1 of 2

1 RENE L. VALLADARES
Federal Public Defender
2 State Bar No. 11479
BRIAN PUGH
Assistant Federal Public Defender
3 Law Office of the Federal Public Defender
411 E. Bonneville Avenue, Suite 250
4 Las Vegas, Nevada 89101
(702) 388-6577/Phone
5 (702) 388-6261/Fax
Brian_Pugh@fd.org
6 Attorney for Karen Chapon

7 UNITED STATES DISTRICT COURT
8 DISTRICT OF NEVADA
-oOo-
9
UNITED STATES OF AMERICA, )
10 ) Case No: 2:20-cr-286-JCM-NJK
Plaintiff, )
) EMERGENCY STIPULATION TO
11 ) MODIFY CONDITIONS OF RELEASE
vs. ) (EXPEDITED TREATMENT
12 ) REQUESTED)
KAREN CHAPON, )
13 )
Defendant. )
14 )

15 IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou,

16 Acting United States Attorney, and Jessica Oliva, Assistant United States Attorney, and Rene L.

17 Valladares, Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel

18 for Karen Chapon, that Ms. Chapon’s pretrial release travel condition be amended to allow Ms.

19 Chapon to travel to the State of Colorado as outlined in paragraph 5, below.

20 This stipulation is entered into for the following reasons:

21 1. Ms. Chapon’s father is dying of cancer and was recently placed in the care of

22 hospice. The defense has provided her pretrial services officer and the government with

23 verification of hospice care.

24
Case 2:20-cr-00286-JCM-NJK Document 55 Filed 07/09/21 Page 2 of 2

1 2. Ms. Chapon requests that she be permitted to travel to Colorado to visit her father

2 before he passes. There may not be much time before her father passes.

3 3. Ms. Chapon has been on pretrial supervision for eight months. During that time,

4 she has had a minor violation which is being addressed by Ms. Chapon agreeing to forfeit her

5 medical marijuana card.

6 4. Ms. Chapon’s pretrial services officer has no objection to modifying her

7 conditions of release to permit travel to the State of Colorado.

8 5. Ms. Chapon has arranged to fly to Colorado on Friday, July 9, 2021, stay in the

9 home of her parents, and return on July 26, 2021. More detailed information, including her

10 parent’s address, was provided to her pretrial services officer.

11 6. The parties agree to this modification.

12 Dated this 9th day of July 2021.

13 RENE L. VALLADARES Christopher Chiou
Federal Public Defender Acting United States Attorney
14
By /s/ Brian Pugh_______________ By /s/ Jessica Oliva _______
15 BRIAN PUGH JESSICA OLIVA
Assistant Federal Public Defender Assistant U.S. Attorney
16 Counsel for Defendant

17
ORDER
18
IT IS SO ORDERED.
19
_____________________________
20 BRENDA WEKSLER
United States Magistrate Judge
21 July 9, 2021
DATED: _____________________
22 2

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Our copy: gov.uscourts.nvd.146469.56.0.pdf
Original: archive.org