2:25-cr-00247•USA v. Tolentino et al
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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 ERIC V. KERSTEN, #226429 Attorney at Law 1125 T Street Fresno, CA 93721 Telephone: (559) 326-6258 eric@kerstenlegal.com Attorney for Defendant Vanessa Flores-Gomez IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA UNITED STATES OF AMERICA, Plaintiff, v. VANESSA FLORES-GOMEZ Defendant. Case No. 2:25-cr-00247-DJC STIPULATION TO MODIFY CONDITIONS OF PRETRIAL RELEASE, [PROPOSED] ORDER Judge: Sean C. Riordan IT IS HEREBY STIPULATED by and between the parties, through their respective counsel, Robert Abendroth, Assistant United States Attorney, counsel for plaintiff, and Eric V. Kersten, counsel for defendant Vanessa Flores-Gomez, that Ms. Flores-Gomez’ conditions of Pretrial Release may be modified to reduce her location monitoring condition from home detention to curfew. On October 29, 2025, Vanessa Flores-Gomez appeared before the Hon. Carolyn K. Delaney and was ordered released on conditions of Pretrial Supervision including: 13. HOME DETENTION: You must remain inside your 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 essential activities pre-approved by the pretrial services officer. Essential activities include haircuts, DMV appointments, banking needs, or other activities that cannot be completed by another person on your behalf. (ECF 11:1).
-2- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Flores-Gomez: Stipulation to Modify Conditions of Pretrial Release Conditions; [Proposed] Order On December 17, 2025, Ms. Flores-Gomez’s conditions were modified to allow her to “reside at a location approved by the pretrial services officer and not move or absent [her]self from this residence for more than 24 hours without the prior approval of the pretrial services officer;” but the home detention condition remained unchanged. (ECF 78, 80). It is now requested that the location monitoring condition be modified to replace the home detention condition with a curfew condition providing: 13. CURFEW: You must remain inside your residence every day from 7:00am to 9:00pm, or as adjusted by the pretrial services officer for medical, religious services, employment or court-ordered obligations. Pretrial Services reports Ms. Flores-Gomez has been under PTS supervision since October 30, 2025, and has remained in overall compliance with her conditions of release, including home detention. Pretrial Services has reviewed this stipulation and supports the proposed modification. All other conditions of Ms. Flores-Gomez’s pretrial release shall remain in full force and effect. Respectfully submitted, ERIC GRANT United States Attorney DATED: January 7, 2026 /s/ Robert Abendroth ROBERT ABENDROTH Assistant United States Attorney Attorney for Plaintiff DATED: January 7, 2026 /s/ Eric V. Kersten ERIC V. KERSTEN Attorney at Law Attorney for Defendant Vanessa Flores-Gomez.. /// /// /// ///
-3- 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Flores-Gomez: Stipulation to Modify Conditions of Pretrial Release Conditions; [Proposed] Order ORDER IT IS SO ORDERED. Special Condition 13 of the Order Setting Conditions of Pretrial Release for Vanessa Flores-Gomez is modified as set forth above. DATED: January 7, 2026.
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