USA v. Nolan

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KYLE R. KNAPP (SBN 166597)
ATTORNEY AT LAW
916 2nd Street, 2nd Floor
Sacramento, CA. 95814
Tel. (916) 441-4717
Fax (916) 441-4299
E-Mail: kyleknapp@sbcglobal.net
Attorney for Defendant
SONNY NOLAN
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
SONNY NOLAN.,
Defendant.
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No. 25-CR-00166-DJC
[PROPOSED] ORDER REGARDING
AMENDING DEFENDANT’S SPECIAL
CONDITIONS OF RELEASE
Date:
Time: .
Judge: Honorable Jeremy D. Peterson
Defendant, Sonny Nolan, seeks to amend the Court’s previously issued Pretrial Release
order issued by the Honorable Carolyn Delaney on July 29, 2025. Since his release, Mr. Nolan
has been compliant with his conditions of pretrial release. Mr. Nolan’s pretrial services officer
Lorena Gallagher contacted counsel and asked counsel to prepare a stipulation modifying
existing condition 12.-Home Incarceration to:
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.

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The request is based on Mr. Nolan’s compliance with all conditions of release including
location monitoring since his release. He also wishes to do community service and seek gainful
employment while the case is pending.
The prayer is that condition 12 be modified. Modified conditions of release are attached
to this pleading as exhibit A. One of the three sureties needs to be removed. The defendant and
the remaining two sureties have been notified, been advised and have signed new paperwork,
consenting to dropping the third individual from the unsecured bond.
Assistant United States Attorney Alex Cardenas, does not oppose the modification
Condition 12 of the Release Conditions. 	He also supports removing the third individual from
the unsecured bond package.
IT IS HEREBY stipulated between the United States of America thought its undersigned
counsel, Alex Cardenas, Assistant United States Attorney, attorney for plaintiff and Kyle
Knapp, attorney for defendant Sonny Nolan, that his Amended Special Conditions of Release as
detailed in Exhibit A be adopted. 	Also, that the third surety be dropped and the third-party
custodian, Kayla Wheeler and Ronica Rackley remain as sureties.
All other terms and conditions and release will remain the same.
Dated: November 25, 2025 	/s/ Kyle Knapp
KYLE KNAPP
Attorney for Defendant
SONNY NOLAN
Dated: November 25, 2025 	ERIC GRANT
UNITED STATES ATTORNEY
By: 	/s/Alex Cardenas
Alex Cardenas
Assistant U.S. Attorney
Attorney for Plaintiff

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[ PROPOSED] ORDER
The Stipulation of the parties is hereby accepted, and the Amended Special Conditions
of Release for Mr. Nolan attached as “Exhibit A” are hereby adopted. Also, it is hereby ordered
that the third surety be removed and Kayla Wheeler and Ronica Rackley remain on the bond.
IT IS SO ORDERED.
Dated: November 26, 2025 	_______________________________
HON. JEREMY D. PETERSON
United States Magistrate

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Ex. A
AMENDED SPECIAL 	CONDITIONS 	OF 	RELEASE
Re: Sonny Nolan
No.: 2:25-CR-00166-DJC
Date: November 25, 2025
1. 	You must report to and comply with the rules and regulations of the Pretrial
Services Agency;
2. 	You must reside at a location approved by the pretrial services officer and
not move or absent yourself from this residence for more than 24 hours
without the prior approval of the pretrial services officer;
3. 	You must cooperate in the collection of a DNA sample;
4. 	You must restrict your travel to the Eastern District of California, unless
otherwise approved in advance by the pretrial services officer;
5. 	You must not apply for or obtain a passport or any other travel documents
during the pendency of this case;
6. 	You 	must 	not 	possess, 	have 	in 	your 	residence, 	or 	have 	access 	to 	a
firearm/ammunition, 	destructive 	device, 	or 	other 	dangerous 	weapon;
additionally, 	you 	must 	provide 	written 	proof 	of 	divestment 	of 	all
firearms/ammunition currently under your control;
7. 	You must refrain from excessive use of alcohol;
8. 	You must not use or possess any narcotic drug or other controlled substance
without a prescription by 	a 	licensed 	medical 	practitioner; 	and you 	must
notify 	Pretrial 	Services 	immediately 	of 	any 	prescribed 	medication(s).
However, medicinal marijuana prescribed and/or recommended may not be
used.
9. 	You must submit to drug and/or alcohol testing. You must pay all or part of the
costs of the testing services based upon your ability to pay, as determined by
the pretrial services officer. You must not tamper, obstruct, or attempt to
tamper or obstruct the efficiency and accuracy of the drug screening/testing;

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10. 	You must report any contact with law enforcement to your pretrial services
officer within 24 hours;
11. 	You must participate in the following location monitoring program component
and abide by all the requirements of the program, which will include having a
location monitoring unit installed in your residence and a radio frequency
transmitter 	device 	attached 	to 	your 	person. 	You 	must 	comply 	with 	all
instructions for the use and
operation of said devices as given to you by the Pretrial Services Agency and
employees of the monitoring company. You must pay all or part of the costs of
the program based upon your ability to pay, as determined by the pretrial
services officer;
12. 	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.
13. 	Your release on bond will be delayed until Wednesday, July 30, 2025, at 9:00
am, at which time you must report immediately to the U.S. Pretrial Services
Agency, located at 501 I Street, Suite 2- 400, Sacramento, California, for the
installation of the location monitoring equipment;
14. 	You must participate in a cognitive behavioral therapy program as directed by
the pretrial services officer. Such programs may include group sessions led by a
counselor or participation in a program administered 	by the Pretrial Services
Agency;
15. 	Upon 	completion 	of 	the 	cognitive 	behavioral 	therapy 	program, 	you 	must
participate in the Better Choices court program and comply with all the rules
and 	regulations 	of 	the 	program. 	You 	must remain 	in 	the 	program 	until
released 	by 	a 	pretrial 	services 	officer. 	In 	accordance 	with 	this condition,
you must appear before the Honorable Jeremy D. Peterson, as directed by the
pretrial services officer; and

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16. 	You must have no contact with any known gang members or associates of
the 	East 	Side 	Airport 	Crew 	(ESAPT), 	the "Peckerwoods," 	or 	"Sureno"
gangs.