Seventh Stipulation to Modify Conditions of Release — United States v. Karen Chapon, No. 2:20-cr-286-JCM-NJK (Dkt. 84, D. Nev.)

Summary

In this Seventh Stipulation to Modify Conditions of Release in United States v. Karen Chapon (D. Nev., Case No. 2:20-cr-286-JCM-NJK), the government and the Federal Public Defender agree that Ms. Chapon's pretrial release travel condition be amended to allow travel to Colorado. The stipulation states that on March 11, 2022 the court expanded the travel restriction to include California, with prior Pretrial Services approval, so that Ms. Chapon could work and care for an elderly mother, who has since moved to Colorado. Ms. Chapon asks to be allowed to travel to Colorado to care for the mother, with prior Pretrial Services approval, and the Pretrial Services Officer does not object. The stipulation is dated September 20, 2022; the order beneath it, 'IT IS SO ORDERED', is dated September 21, 2022 over the name of U.S. Magistrate Judge Brenda Weksler.

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Full text

Case 2:20-cr-00286-JCM-NJK Document 83
84 Filed 09/20/22
09/21/22 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, )
) SEVENTH STIPULATION TO
11 ) MODIFY CONDITIONS OF RELEASE
vs. )
12 )
KAREN CHAPON, )
13 )
Defendant. )
14 )

15 IT IS HEREBY STIPULATED AND AGREED, by and between Jason Frierson, United

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

17 Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel for Karen

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

19 travel to Colorado as outlined below.

20 This stipulation is entered into for the following reasons:

21 1. On March 11, 2022, the Court modified Ms. Chapon’s pretrial release conditions

22 to expand her travel restriction to include travel California with prior Pretrial Services approval.

23 ECF No. 79. This modification was made to allow Ms. Chapon to travel to California for work

24 and to care for her elderly mother. Id.
Case 2:20-cr-00286-JCM-NJK Document 83
84 Filed 09/20/22
09/21/22 Page 2 of 2

1 2. Since the Court granted the modification, Ms. Chapon’s mother moved to

2 Colorado.

3 3. Ms. Chapon requests that her travel restriction be modified to also permit her to

4 travel to Colorado for the purpose of caring for her mother with prior Pretrial Services Approval.

5 4. Ms. Chapon’s Pretrial Services Officer does not object to this modification to her

6 release conditions.

7 5. The parties agree to this modification.

8 Dated this 20th day of September 2022.

9 RENE L. VALLADARES JASON FRIERSON
Federal Public Defender United States Attorney
10
By /s/ Brian Pugh_______________ By /s/ Jessica Oliva _______
11 BRIAN PUGH JESSICA OLIVA
Assistant Federal Public Defender Assistant U.S. Attorney
12

13 ORDER

14 IT IS SO ORDERED.

15
_____________________________
16 BRENDA WEKSLER
United States Magistrate Judge
17

18 DATED: _____________________
September 21, 2022

22 2

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