United States v. Kimura

2:15-cr-00161-WBS | E.D. Cal. | Dec 19, 2016

Case 2:15-cr-00161-GEB Document 89 Filed 12/19/16 Page 1 of 2 1 Adam J. Krolikowski (SBN 202946)

T HE K ROLIKOWSKI L AW F IRM 18022 Cowan, Suite 235 Irvine, California 92614 T. (949) 269-1869 F. (949) 269-1868 Email: adam@usethelaw.com Attorneys for Robert Turchin

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, ) Case No.: 2:15-CR-0161 GEB ) Before the Hon. Garland E. Burrell, Jr Plaintiff, ) ) vs. ) STIPULATION AND [PROPOSED] ) ORDER TO MODIFY THE ANDREW KIMURA, PAVITAR ) CONDITIONS OF PRETRIAL DOSANGH SING, ) RELEASE aka “Peter Singh” ) aka “Pavitar Dosanjh Singh” ) MANGAL GILL, and ) ROBERT TURCHIN, )

) Defendants. ) ) THE PARTIES HEREBY STIPULATE AND AGREE that the conditions of pretrial release imposed on defendant, ROBERT TURCHIN, may be modified to allow him to travel to and within the State of Nevada between the dates of December 28, 2016 and January 6, 2017, without a court order, but with notification to pretrial. As discussed between counsel, Mr. Turchin has a pre-paid family vacation (purchased in April 2016) for the New Year’s Holiday for the indicated time period STIPULATION AND [PROPOSED] ORDER TO MODIFY THE CONDITIONS

OF PRETRIAL RELEASE - 1 Case 2:15-cr-00161-GEB Document 89 Filed 12/19/16 Page 2 of 2 1 in the State of Nevada and requests permission to be able to travel and vacation with his family over the New Year’s holiday as planned. Mr. Turchin has discussed this with Pretrial Services. The exact itinerary consists of departing from San Jose, CA on December 29, 2016 at 12:20 p.m. and returning January 06, 2017 at 4:20 p.m. by Southwest Airline. Mr. Turchin’s stay consists of December 29 to January 02 at the Wyndham Grand Desert, 265 East Harmon Ave, Las Vegas and January 02 to January 06 at the Marriott Grand Chateau, 75 East Harmon Ave, Las Vegas. This will be a time spent with family together for New Year’s. It is the request of the parties to modify the conditions of pretrial release which would permit Mr. Turchin to travel to and throughout the State of Nevada with his family for the New Year’s Holiday between the dates of December 28, 2016 and January 6, provided he give notice to pretrial services. Pretrial Services is amendable to this request. Dated: December 16, 2016 ___Adam J. Krolikowski __

T HE K ROLIKOWSKI L AW F IRM Adam J. Krolikowski, Esq. for Defendant Robert Turchin
Dated: December 16, 2015 _ Todd A. Pickles _ Todd A. Pickles, Esq. Assistant U.S. Attorney

U.S. ATTORNEY’S OFFICE

IT IS SO ORDERED.

Dated: December 16, 2016

STIPULATION AND [PROPOSED] ORDER TO MODIFY THE CONDITIONS

OF PRETRIAL RELEASE

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