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Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 11)

Summary

Defendant Cassie Will-Darnall, through the Federal Public Defender, files an unopposed motion and proposed order to temporarily modify the conditions of pretrial release. The motion asks for permission to travel to Groveland, California, in the Eastern District of California, from June 26, 2024, to June 30, 2024, to perform maintenance on her property. It also asks for travel to Reno, Nevada, from July 12, 2024, to July 14, 2024, to attend a birthday celebration. Counsel states that a Pretrial Services Officer and Assistant United States Attorney Sarah Griswold do not object. The proposed order for Hon. Susan van Kuelen states that all other conditions remain in full effect and has a blank date line.

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“Unopposed Motion and Proposed Order Temporarily Modifying Conditions of Pretrial Release — United States v. Cassie Will-Darnall (Dkt. 11).” Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/gov-uscourts-cand-430212-11-0-a815f4655b/, SHA-256 69612b9cef91355adee837e88e29a567ba1618e4347b1201b9528b23c2d96b7c.

Full text

              Case 5:24-cr-00292-PCP                  Document 11          Filed 06/25/24    Page 1 of 2



 1   JODI H. LINKER
     Federal Public Defender
 2
     VARELL L. FULLER
 3   Assistant Federal Public Defender
     55 S. Market Street, Suite 820
 4   San Jose, CA 95113
 5
     Telephone: (408) 291-7753
     Varell_Fuller@fd.org
 6
     Counsel for Defendant WILL-DARNALL
 7

 8
                                         UNITED STATES DISTRICT COURT
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                                      NORTHERN DISTRICT OF CALIFORNIA
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                                                    SAN JOSE DIVISION
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     UNITED STATES OF AMERICA,                                     No. 24-CR-00292 PCP (SVK)
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                        Plaintiff,
14                                                                 UNOPPOSED MOTION AND [PROPOSED]
              vs.                                                  ORDER TEMPORARILY MODIFYING
15                                                                 CONDITIONS OF PRETRIAL RELEASE
     CASSIE WILL-DARNALL,
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                        Defendant.                                 Judge: Hon. Susan van Kuelen
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18            Defendant Cassie Will-Darnall, by and through counsel, respectfully requests that the

19   Court temporarily modify her pretrial release conditions to permit her travel to Groveland,
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     California, located in the Eastern District of California, from June 26, 2024, to June 30, 2024, to
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     perform maintenance on her property. Additionally, Ms. Will-Darnall requests that the Court
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     modify her conditions of release to permit her to travel to Reno, Nevada, from July 12, 2024, to

24   July 14, 2024, to attend a birthday celebration.
25            Counsel for Ms. Will-Darnall has conferred with Pretrial Services Officer Emily Sanchez
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     and Assistant United States Attorney Sarah Griswold, and they do not object to this
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     modification.
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     //
     Motion to Temporarily Modify Conditions of Pretrial Release
     WILL-DARNALL, 20-CR-458 BLF
              Case 5:24-cr-00292-PCP                  Document 11       Filed 06/25/24    Page 2 of 2



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     Dated: June 25, 2024                                          JODI H. LINKER
 3                                                                 FEDERAL PUBLIC DEFENDER

 4                                                                 __________/s/_______________
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                                                                   VARELL L. FULLER
                                                                   Assistant Federal Public Defender
 6

 7                                                 [PROPOSED] ORDER
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              GOOD CAUSE APPEARING, upon the defendant’s unopposed motion, IT IS HEREBY
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     ORDERED that the defendant’s pretrial release conditions are temporarily modified to permit
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11   the defendant to travel from San Jose to the Eastern District of California, from June 26, 2024,

12   to June 30, 2024.
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              IT IS HEREBY FURTHER ORDERED that the defendant’s pretrial release conditions
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     shall also be temporarily modified to permit the defendant to travel from San Jose to Reno,
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     Nevada, from July 12, 2024, to July 14, 2024.
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17            All other conditions are to remain in full effect.

18            IT IS SO ORDERED.
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     DATED: ___________                    _________________________________________
20                                         THE HONORABLE SUSAN van KUELEN
                                           United States Magistrate Judge
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     Motion to Temporarily Modify Conditions of Pretrial Release
     WILL-DARNALL, 20-CR-458 BLF

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