USA v. Tolentino et al

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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).

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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..
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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.