Opinion
LAW OFFICES OF JOHNNY L. GRIFFIN III JOHNNY L. GRIFFIN III, Sacramento, California, Attorney for Defendant BENJAMIN CUNHA.
STIPULATION AND [PROPOSED] ORDER TO MODIFY CONDITION OF PRETRIAL RELEASE TO ALLOW DEFENDANT TO BE AWAY FROM HIS RESIDENCE FOR HIS WEDDING AND RECEPTION.
ALLISON CLAIRE, Magistrate Judge.
Plaintiff United States of America, by and through its counsel of record, and Defendant, by and through his counsel of record, hereby stipulate and agree as follows:
1. Defendant is out of custody on home detention and being monitored by Pretrial Services.
2. Defendant is restricted to his residence at all times except for employment, education, religious services, medical, substance abuse, or mental health treatment, attorney visits, court appearances, court-ordered obligations, or other activities pre-approved by the pretrial services officer.
3. Defendant and his fiance Amber Gronstal have scheduled their wedding for Saturday September 26, 2015 at 5:00p.m. at the Ed Hagen Ranch, 6341 Hagen Ranch Rd., El Dorado, California, 95623.
Defendant and his fiance (and their families) hurriedly scheduled this wedding date and time in light of the uncertainty of Defendant's custody status once he enters his guilty plea on October 6, 2015. Specifically, the Government and Defendant have reached a plea agreement wherein both sides have reserved the right to argue the timing of Defendant's remand into custody.
4. Following the wedding ceremony, the wedding reception and dinner will commence at this same location.
5. Defendant and his fiance anticipate approximately 100-125 guests to attend to the wedding, reception and dinner.
6. U.S. Pretrial Services Officer Renee Basurto has confirmed the above wedding and reception location and date.
7. Defendant requests permission to be away from his residence on September 26, 2015. Specifically, Defendant will be away from his residence on September 26, 2015 from 7:00 a.m. to 11:59 p.m.
8. Defendant's parents/third party custodians will be with him at the wedding and reception and have agreed to report any known violations to Pretrial Services.
9. Accordingly, the parties agree and stipulate to modify defendant's home detention to allow him to attend his wedding and reception, wherein he can be leave his home on September 26, 2015 at 7:00 a.m. and return no later than 11:59 p.m. on September 26, 2015.
IT IS SO STIPULATED.
IT IS SO ORDERED.