Stipulation to Modify Conditions of Release — United States of America v. Karen Chapon, Case No. 2:20-cr-286-JCM-NJK (Dkt. 62, D. Nev.)

Summary

In this stipulation filed 07/23/21 in the District of Nevada, Case No. 2:20-cr-286-JCM-NJK, the government and the Federal Public Defender agree to amend the pretrial release travel condition of Karen Chapon to allow a stay in Colorado until August 19, 2021. The stipulation says the Court had on July 9, 2021 permitted travel to Colorado from July 9 to July 26, 2021 for a visit to Ms. Chapon’s father in hospice care, and that the father died and Ms. Chapon asked to stay for the funeral and to help settle final affairs. Ms. Chapon agrees to drug testing in the District of Colorado, and the Pretrial Services Officer does not oppose the change if that testing can be arranged. An order reading IT IS SO ORDERED, above the name of United States Magistrate Judge Brenda Weksler, is dated 7/23/2021.

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Case 2:20-cr-00286-JCM-NJK Document 62 Filed 07/23/21 Page 1 of 3

RENE L. VALLADARES

Federal Public Defender

State Bar No. 11479

BRIAN PUGH

Assistant Federal Public Defender
Law Office of the Federal Public Defender
411 E. Bonneville Avenue, Suite 250
Las Vegas, Nevada 89101

(702) 388-6577/Phone

(702) 388-6261/Fax
Brian_Pugh@fd.org

Attorney for Karen Chapon

UNITED STATES DISTRICT COURT

DISTRICT OF NEVADA
UNITED STATES OF AMERICA, )
) Case No: 2:20-cr-286-JCM-NJK
Plainuft, ) | STIPULATION TO MODIFY
vs ) CONDITIONS OF RELEASE
)
)
KAREN CHAPON, )
)
Defendant.

IT IS HEREBY STIPULATED AND AGREED, by and between Christopher Chiou,
Acting United States Attorney, and Jessica Oliva, Assistant United States Attorney, and Rene L.,
Valladares, Federal Public Defender, and Brian Pugh, Assistant Federal Public Defender, counsel]
for Karen Chapon, that Ms. Chapon’s pretrial release travel condition be amended to allow Ms|
Chapon to stay in Colorado as outlined below.

This stipulation is entered into for the following reasons:

1. On July 9, 2021, the Court modified Ms. Chapon’s conditions of pretrial release
to permit her to travel to Colorado from July 9 to July 26, 2021 to visit her father, who had been

admitted to hospice care. ECF No. 56.
10

Case 2:20-cr-00286-JCM-NJK Document 62 Filed 07/23/21 Page 2 of 3

2. Ms. Chapon’s father died, and she requests to stay for the funeral and help her
mother settle her father's final affairs.

3. Ms. Chapon requests that she be permitted to stay in Colorado until August 19,
2021.

4. Ms. Chapon has been on pretrial supervision for eight months. During that time,
she has had a minor violation which was addressed by Ms. Chapon agreeing to forfeit her medical
marijuana card.

5. Ms. Chapon’s Pretrial Services Officer does not oppose this modification if
Pretrial Services is able to arrange for drug testing in the District of Colorado. Ms. Chapon’s
Pretrial Services Officer is in the process of determining whether doing so will be possible. Ms.
Chapon agrees to submit to drug testing in the District of Colorado during her time there from the
date of this stipulation through her return to the District of Nevada.

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Dated this 23" day of July 2021.

RENE L. VALLADARES
Federal Public Defender

By /s/ Brian Pugh

BRIAN PUGH

Assistant Federal Public Defender
Counsel for Defendant

ORDER

IT IS SO ORDERED.

BRENDA WEKSLER
United States Magistrate Judge

DATED: 7/23/2021

6. The parties agree to this modification.

Case 2:20-cr-00286-JCM-NJK Document 62 Filed 07/23/21 Page 3 of 3

Christopher Chiou
Acting United States Attorney

By /s/ Jessica Oliva

JESSICA OLIVA
Assistant U.S. Attorney

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