USA v. Collins

1	STIPULATION RE MODIFICATION OF PRETRIAL
RELEASE CONDITIONS
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KELLAN S. PATTERSON, SB No. 307190
info@kellanpatterson.com
LAW OFFICE OF KELLAN PATTERSON
2450 Venture Oaks Way, Suite 200
Sacramento, CA 95833
Tel: 916.905.7265
Fax: 916.721.2742
Attorneys for Defendant
MAURICE COLLINS
IN THE UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
UNITED STATES OF AMERICA,
Plaintiff,
v.
MAURICE COLLINS,
Defendant.
CASE NO. 2:25-CR-00032-DJC
STIPULATION TO MODIFY PRETRIAL
RELEASE CONDITIONS; [PROPOSED] ORDER
DATE: February 13, 2026
TIME: 2:00 p.m.
COURT: Hon. Jeremy D. Peterson
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant Maurice
Collins, by and through his counsel of record, hereby stipulate as follows:
1. By previous order, Magistrate Judge Sean C. Riordan ordered Defendant Maurice Collins
released on May 27, 2025. (ECF No. 28).
2. Furthermore, Special Conditions of Release were issued as to Maurice Collins. (ECF No.
29).
3. On June 6, 2025, Hon. Jeremy D. Peterson issued an order modifying Maurice Collins’
release conditions. (ECF No. 36).
4. United States Pretrial Services of the Eastern District of California has noted that
Maurice Collins has been in continued compliance with his conditions of release, and has had stable
housing, employment and participation with treatment services. As a result, Pretrial Services is
recommending that the location monitoring conditions be removed.

2	STIPULATION RE MODIFICATION OF PRETRIAL
RELEASE CONDITIONS
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5. By this stipulation, the parties now move to modify Maurice Collins’ Special Conditions
of Release to remove conditions 15 and 16 which pertain to location monitoring conditions.
6. All previous conditions outlined in the Special Conditions of Release ordered on May 27,
2025, remain in effect.
IT IS SO STIPULATED.
Dated: February 12, 2026 ERIC GRANT
Acting United States Attorney
/s/ NICOLE VANEK
NICOLE VANEK
Assistant United States Attorney
Dated: February 12, 2026 /s/ KELLAN PATTERSON
KELLAN PATTERSO
Counsel for Defendant
MAURICE COLLINS
Dated: February 12, 2026
NAFEESHA DOBSON
Bond Surety for Defendant
Dated: February 12, 2026
CHARMAINE STRAUGHTER
Bond Surety for Defendant
Dated: February 12, 2026
AMBER NEWSOME
Bond Surety for Defendant
Dated: February 12, 2026
ANGELA GILMORE
Bond Surety for Defendant

3	STIPULATION RE MODIFICATION OF PRETRIAL
RELEASE CONDITIONS
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[PROPOSED] ORDER
IT IS SO ORDERED.
Dated: February 13, 2026
JEREMY D. PETERSON
UNITED STATES MAGISTRATE JUDGE