3:20-mj-70028 | N.D. Cal. | Apr 13, 2021

Case 3:20-mj-70028-MAG Document 60 Filed 04/13/21 Page 1 of 2

ISMAIL RAMSEY (Bar No. 189820) izzy@ramsey-ehrlich.com KATHARINE KATES ((Bar No. 155534) katharine@ramsey-ehrlich.com RAMSEY & EHRLICH LLP 803 Hearst Avenue Berkeley, CA 94710 (510) 548-3600 (Tel) (510) 291-3060 (Fax) Attorneys for Defendant Mohammed Nuru

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) ) ) ) ) ) ) ) Case No.: CR 20-70028 MAG Case No.: CR 20-70076 MAG UNITED STATES OF AMERICA, Plaintiff, STIPULATION AND [PROPOSED] ORDER TO MODIFY BAIL CONDITIONS vs. MOHAMMED NURU, Defendant. The defendant Mohammed Nuru is currently scheduled to appear before this Court for status and preliminary hearing or indictment on April 13, 2021 at 10:30 am. This court has previously ordered Mr. Nuru released on bail, with a $2 million bond, with $400,000 of that amount secured by a deed of trust on his primary residence. Mr. Nuru has complied with all of the terms of his pretrial release and supervision, without any violations. Mr. Nuru has requested to travel to his home in Stonyford, Colusa County, to perform maintenance for the weekends of April 9 to April 12, 2021, May 13 to May 17, 2021, and June 30, 2021, to July 5, 2021. His supervising pretrial services officer does not object to this request.

1 Stipulation and [Proposed] Order Case 3:20-mj-70028-MAG Document 60 Filed 04/13/21 Page 2 of 2 Accordingly, the United States and Mr. Nuru stipulate and move this court to modify the bail conditions to allow Mr. Nuru to travel to his home in Stonyford for the two above-described periods.

All other conditions of Mr. Nuru’s pretrial release, imposed on January 28, 2020, will remain the same.

IT IS SO STIPULATED.

Dated: April 8, 2021 Respectfully Submitted, April 13, 2021 RAMSEY & EHRLICH LLP //s// ____________ ISMAIL RAMSEY KATHARINE KATES Attorneys for MOHAMMED NURU

DAVID L. ANDERSON

United States Attorney //s// _________

SCOTT D. JOINER

S. WAQAR HASIB

Assistant United States Attorneys

GOOD CAUSE HAVING BEEN SHOWN, IT IS SO ORDERED.

Dated: ___________________________________

THE HONORABLE SALLIE KIM

UNITED STATES MAGISTRATE JUDGE

2 Stipulation and [Proposed] Order