USA v. Lucero-Peace et al

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Stipulation and Proposed Order Permitting Travel, Case No. 25-MJ-71257
Matthew M. Yelovich (SBN 351330)
Cleary Gottlieb Steen & Hamilton LLP
1841 Page Mill Road, Suite 250
Palo Alto, CA 94304
(650) 815-4100
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,
Plaintiffs,
v.
JULIO JOVAN VASQUEZ-OCHOA,
Defendant.
Case No. 25-MJ-71257
STIPULATION AND [PROPOSED]
ORDER PERMITTING TRAVEL
FROM THE DISTRICT
Pursuant to the Court’s order permitting travel from the district, defendant, Julio Jovan
Vasquez-Ochoa, may travel to Elk Grove between December 24, 2025 through December 27,
2025 to visit family members. Dkt No. 14. Mr. Vasquez-Ochoa, represented by undersigned
counsel Matthew Yelovich, has requested that he be permitted to extend his travel to Elk Grove,
California from December 27, 2025 to December 30, 2025, in order to assist his father with a job
moving a family from one house to another. The government, represented by Assistant United
States Attorney, Neal Hong, has no objection to this request.
Case 5:26-cr-00048-EKL Document 16 Filed 12/24/25 Page 1 of 3

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Stipulation and Proposed Order Permitting Travel, Case No. 25-MJ-71257
Accordingly, the parties hereby stipulate that defendant Vasquez-Ochoa be permitted to
extend his travel from the Northern District of California, to Elk Grove, in the Eastern District of
California, from December 27, 2025 to December 30, 2025.1
Respectfully submitted,
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: December 23, 2025 	/s/ Matthew M. Yelovich
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: December 23, 2025 	/s/ Neal Hong
NEAL HONG
Assistant United States Attorney
1 Undersigned counsel attests that each of the other signatories have concurred in the filing of the
document.
Case 5:26-cr-00048-EKL Document 16 Filed 12/24/25 Page 2 of 3

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Stipulation and Proposed Order Permitting Travel, Case No. 25-MJ-71257
[PROPOSED] ORDER
Pursuant to the parties’ stipulation and for good cause shown, the Court HEREBY
ORDERS that defendant Julio Jovan Vasquez Ochoa may extend the travel from his residence in
the Northern District of California, to Elk Grove, California, between the dates of December 27,
2025 and December 30, 2025.
PURSUANT TO STIPULATION IT IS SO ORDERED.
Dated: __________________
_________________________
United States Magistrate Judge
December 24, 2025
VIRGINIA K. DEMARCHI
Case 5:26-cr-00048-EKL Document 16 Filed 12/24/25 Page 3 of 3