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’s conditions of
Pretrial Release may be modified to allow her to reside at a location approved in advance by her
pretrial services officer.
On October 29, 2025, Vanessa Flores-Gomez appeared before the Hon. Carolyn K.
Delaney and was ordered released on conditions of Pretrial Supervision including:
3. You must reside with your aunt, Margarita Flores-Castros, and not
move or absent yourself from this residence for more than 24 hours
without the prior approval of the pretrial services officer;
(ECF 11: 1)

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Flores-Gomez: Stipulation to Modify
Conditions of Release; Proposed Order
Ms. Flores-Gomez and her three children, two toddlers and a 9-year-old, currently reside
with Vanessa’s aunt, Margarita Flores-Castro. Margarita’s husband and three children also reside
at that location. That residence was selected due to concerns about Vanessa returning to her prior
residence because she is charged with having stored contraband at that location when her
children were present. Margarita is not a third-party custodian. Her residence was chosen
because she was willing to provide alternative housing for Vanessa.
Vanessa is requesting permission to move to an apartment near her daughter’s school in
Marysville for several reasons. First, it is very crowded at Margarita’s apartment. Vanessa and
her children are residing in a single bedroom that was previously occupied by Margarita’s 17-
year-old daughter, a high school student who is now sleeping on the couch. Obviously, that is not
ideal. And given that six children are now residing in Margarita’s apartment it is somewhat
chaotic. Another very significant reason is that Margarita’s apartment is located 15-20 minutes
away from the elementary school attended by Vanessa's 9-year-old daughter, and it is not always
possible to arrange transportation to and from school.
Vanessa and her husband, who is not charged in the offense, would like to move to an
apartment near her daughter’s school that would be subject to preapproval by Pretrial Services.
All other conditions of pre-trial release would remain in full force and effect, including
electronic monitoring and home detention. To facilitate the move it is requested that Ms. Florres-
Gomez’s conditions of Pretrial Supervision be modified to provide:
3. 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;
Pretrial Services has reviewed this stipulation and proposed modification proposed
modification and does not object.
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Flores-Gomez: Stipulation to Modify
Conditions of Release; Proposed Order
Respectfully submitted,
ERIC GRANT
United States Attorney
DATED: December 16, 2025 	/s/ Robert Abendroth
ROBERT ABENDROTH
Assistant United States Attorney
Attorney for Plaintiff
DATED: December 16, 2025 	/s/ Eric V. Kersten
ERIC V. KERSTEN
Attorney at Law
Attorney for Defendant
Vanessa Flores-Gomez
ORDER
IT IS SO ORDERED. Special Condition 3 of the Order Setting Conditions of Pretrial
Release for Vanessa Flores-Gomez is modified as set forth above.
DATED: December 16, 2025.
.