USA v. Lucero-Peace et al

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Stipulation and Proposed Order Modifying Conditions of Release, Case No. 5:26-cr-00048
Matthew M. Yelovich (SBN 351330)
Cleary Gottlieb Steen & Hamilton LLP
151 University Avenue
Palo Alto, CA 94301
(650) 815-4152
Email: myelovich@cgsh.com
Attorney for Defendant
JULIO JOVAN VASQUEZ-OCHOA
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
UNITED STATES OF AMERICA,
Plaintiff,
v.
JULIO JOVAN VASQUEZ-OCHOA,
Defendant.
Case No. 5:26-cr-00048-EKL-3
5:25-mj-71257-MAG
STIPULATION AND [PROPOSED]
ORDER MODIFYING CONDITIONS
OF RELEASE
Case 5:26-cr-00048-EKL Document 77 Filed 09/11/26 Page 1 of 5	Case 5:26-cr-00048-EKL Document 81 Filed 09/22/26 Page 1 of 5

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Stipulation and Proposed Order Modifying Conditions of Release, Case No. 5:26-cr-00048
In support of the modification of defendant Julio Jovan Vasquez Ochoa’s conditions of
release requested herein, the parties hereby stipulate as follows:
1. 	On November 7, 2025, Mr. Vasquez Ochoa was ordered released from custody with
pretrial conditions of release. Dkt. 11.
2. 	One of those conditions restricts Mr. Vasquez Ochoa’s travel to the Northern District of
California. Specifically, the Order Setting Conditions of Release provides: “Defendant
must not travel outside of: the Northern District of California.” Id.
3. 	Mr. Vasquez Ochoa has children who reside in Elk Grove, California, in the Eastern
District of California, and therefore frequently wishes to travel there to visit them. He
has sought permission to do so on multiple occasions. Dkt. 14, 16, 45, 58, 65, 67. In
addition, Mr. Vasquez Ochoa’s employment entails travel to the Eastern District of
California, and he has sought and received permission to travel there for work. Dkt. 74.
4. 	In addition, Mr. Vasquez Ochoa has sought and received permission to visit the Central
District of California for his recreational sports league, Dkt. 36, and now anticipates
needing to do so more frequently for his employment, which he anticipates will also
entail travel within the Central District.
5. 	Accordingly, the parties hereby stipulate and agree that Mr. Vasquez Ochoa’s travel
restriction condition be modified to allow for travel to these neighboring districts with
prior notification of dates and locations to the Pretrial Services Officer required if Mr.
Vasquez Ochoa intends to stay overnight outside the Northern District of California.
6. 	Another condition of release requires Mr. Vasquez Ochoa to remain in the custody of
Elizabeth Mendez at 3141 Casa de Campo Apt. 303, San Mateo, California. Dkt. 11.
7. 	Mr. Vasquez Ochoa and Ms. Mendez no longer wish to cohabitate, and Mr. Vasquez
Ochoa plans to move into the house of his mother, Norma Vasquez Ochoa, at 298 Laurel
Grove Lane 131, San Jose, California. In anticipation of his relocation, the parties hereby
stipulate that the custodial condition be removed from Mr. Vasquez Ochoa’s conditions
of release; Ms. Vasquez Ochoa be named his surety; and Ms. Mendez be removed as co-
signer and custodian. Mr. Vasquez Ochoa will continue to reside within the jurisdiction
of his current Pretrial Service Officer, Officer Shafia Khanoon.
Case 5:26-cr-00048-EKL Document 77 Filed 09/11/26 Page 2 of 5	Case 5:26-cr-00048-EKL Document 81 Filed 09/22/26 Page 2 of 5

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Stipulation and Proposed Order Modifying Conditions of Release, Case No. 5:26-cr-00048
8. 	Pretrial Services Officer Shafia Khanoon and Assistant United States Attorney Neal
Hong have no objection to this request.1
1 Undersigned counsel attests that each of the other signatories have concurred in the filing of the
document.
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Stipulation and Proposed Order Modifying Conditions of Release, Case No. 5:26-cr-00048
Respectfully submitted,
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: September 11, 2026 	/s/ Matthew M. Yelovich
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: September 11, 2026 	/s/_Neal Hong____
NEAL HONG
Assistant United States Attorney
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Stipulation and Proposed Order Modifying Conditions of Release, Case No. 5:26-cr-00048
[PROPOSED] ORDER
Pursuant to the parties’ stipulation and for good cause shown, the Court HEREBY
ORDERS that the travel restrictions in defendant Julio Jovan Vasquez Ochoa’s conditions of
release, Dkt. 11, are modified as follows: “Defendant must not travel outside of the Eastern,
Central, and Northern Districts of California, except that Defendant shall provide prior
notification to the Pretrial Services Officer of the dates and location of lodging if staying
overnight outside the Northern District of California.”
The Court FURTHER ORDERS that the Defendant’s pretrial condition of release
requiring that “Defendant must remain in the custody of custodian Elizabeth Mendez at 3141
Casa de Campo Apt. 303, San Mateo California. The Custodian must supervise defendant and
report any violation of a release condition to Pretrial Services. A custodian who fails to do so
may be prosecuted for contempt[]” be removed and that Elizabeth Mendez be removed as co-
signer and custodian.
The Court FURTHER ORDERS that Norma Vasquez Ochoa be named the Defendant’s
surety.
PURSUANT TO STIPULATION IT IS SO ORDERED.
Dated: __________________
_________________________
HON. VIRGINIA DEMARCHI
United States Magistrate Judge
Case 5:26-cr-00048-EKL Document 77 Filed 09/11/26 Page 5 of 5
based on the parties' stipulation and the hearing held on September 22, 2026.
(MODIFIED BY THE COURT)
September 22, 2026
Case 5:26-cr-00048-EKL Document 81 Filed 09/22/26 Page 5 of 5