Third Stipulation to Modify Conditions of Release — United States v. Karen Chapon, No. 2:20-cr-286-JCM-NJK (Dkt. 64, D. Nev.)

Summary

In a third stipulation filed September 7, 2021 in the U.S. District Court for the District of Nevada (Case No. 2:20-cr-286-JCM-NJK), the government and the Federal Public Defender agree to amend Karen Chapon's pretrial release travel condition so that Chapon may travel to Colorado. The stipulation recounts that the Court allowed Colorado travel on July 9, 2021 to visit Chapon's father in hospice care and again on July 23, 2021 for the father's funeral. Chapon asks to return to Colorado on September 9 for the father's Ash Spreading Ceremony and to come back to the District of Nevada on September 19, 2021. Chapon has been on pretrial supervision for more than a year with one minor violation, and the Pretrial Services Officer does not oppose. The order of United States Magistrate Judge Brenda Weksler, dated September 7, 2021, reads 'IT IS SO ORDERED.'

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Full text

Case 2:20-cr-00286-JCM-NJK Document 63
64 Filed 09/07/21 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, )
) THIRD STIPULATION TO MODIFY
11 ) CONDITIONS OF RELEASE
vs. )
12 )
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 Colorado as outlined below.

20 This stipulation is entered into for the following reasons:

21 1. On July 9, 2021, the Court modified Ms. Chapon’s conditions of pretrial release

22 to permit her to travel to Colorado from July 9 to July 26, 2021 to visit her father, who had been

23 admitted to hospice care. ECF No. 56.

24 2. On July 23, 2021, the Court modified Ms. Chapon’s conditions of pretrial release
Case 2:20-cr-00286-JCM-NJK Document 63
64 Filed 09/07/21 Page 2 of 2

1 to permit her to travel to Colorado for the funeral of her father. ECF No. 62.

2 3. Ms. Chapon requests that she be permitted to return to Colorado on September 9,

3 2021, to participate in her deceased father’s Ash Spreading Ceremony. She will return to the

4 District of Nevada on September 19, 2021.

5 4. Ms. Chapon has been on pretrial supervision for more than a year. During that

6 time, she has had a minor violation which was addressed by Ms. Chapon forfeiting her medical

7 marijuana card.

8 5. Ms. Chapon’s Pretrial Services Officer does not oppose this modification to her

9 release conditions.

10 6. The parties agree to this modification.

11 Dated this 7th day of September 2021.

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

16 ORDER

17 IT IS SO ORDERED.

18
_____________________________
19 BRENDA WEKSLER
United States Magistrate Judge
20

21 September 7, 2021.
DATED: _____________________

22 2

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