USA v. Lucero-Peace et al

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28 Stipulation and Proposed Order Permitting Travel, Case No. 26-CR-00048
1
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. 26-cr-00048-EKL-3
25-mj-71257-MAG
STIPULATION AND [PROPOSED]
ORDER PERMITTING TRAVEL
FROM THE DISTRICT
The defendant, Julio Jovan Vasquez Ochoa, represented by undersigned counsel Matthew
Yelovich, has requested that Mr. Vasquez Ochoa be permitted to travel to Sacramento, California
as required by his employer for one day on August 27, 2026. The government, represented by
Assistant United States Attorney, Neal Hong, has no objection to this request. Officer Shafia
Khanoon has indicated on behalf of the Pretrial Services Office that she has no objection to this
request.
Case 5:26-cr-00048-EKL Document 74 Filed 08/26/26 Page 1 of 3

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28 Stipulation and Proposed Order Permitting Travel, Case No. 26-CR-00048
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Accordingly, the parties hereby stipulate that defendant Vasquez Ochoa be permitted to
travel from the Northern District of California, to Sacramento, in the Eastern District of
California, as required by his employer for one day on August 27, 2026.1
Respectfully submitted,
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: August 26, 2026 	/s/ Matthew M. Yelovich
MATTHEW M. YELOVICH
Attorney for Julio Jovan Vasquez-Ochoa
Dated: August 26, 2026 	/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 74 Filed 08/26/26 Page 2 of 3

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28 Stipulation and Proposed Order Permitting Travel, Case No. 26-CR-00048
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[PROPOSED ORDER]
Pursuant to the parties’ stipulation and for good cause shown, the Court HEREBY
ORDERS that defendant Julio Jovan Vasquez Ochoa may travel from his residence in the
Northern District of California to Sacramento, California, in the Eastern District of California as
required by his employer for one day on August 27, 2026.
PURSUANT TO STIPULATION IT IS SO ORDERED.
Dated: __________________
_________________________
HON. SUSAN VAN KEULEN
United States Magistrate Judge
August 26, 2026
Case 5:26-cr-00048-EKL Document 74 Filed 08/26/26 Page 3 of 3