IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF CALIFORNIA
January 23, 2013
UNITED STATES OF AMERICA,
CHRISTOPHER HAYDN-MYER, Bar #176333 1478 Stone Point Drive, Suite 400 Roseville, California 95661 Telephone: (916) 622-1703 Fax: (916)760-2767 email:email@example.com Attorney for Defendant EILEEN KNIGHT
[PROPOSED] ORDER AND STIPULATION BY THE PARTIES REQUESTING THAT EILEEN KNIGHT BE PLACED ON THE FOLLOWING CONDITIONS OF PRETRIAL RELEASE
Plaintiff, the United States of America, by its counsel, Assistant United States Attorney Jason Hitt, defendant Eileen Knight, by her attorney, Christopher Haydn-Myer, hereby jointly request and stipulate that this Court may sign the Proposed Order, ordering that Ms. Knight abide by the following conditions of pretrial release.
The reason for the request is that on December 5, 2012, Ms. Knight completed The Effort's 90 day residential substance abuse treatment program and was permitted to return to her residence in Los Angeles under the previously imposed conditions of release. However, the parties agree that the record needs to be clarified as to what was added and removed at the violation hearing.
U.S. Pretrial Office Steven J. Sheehan is recommending, and the parties are in agreement, that the Court Order that Ms. Knight abide by the following conditions of pretrial release:
1. You shall report to and comply with the rules and regulations of the Pretrial Services Agency;
2. You shall report in person to the Pretrial Services Agency on the first working day following your release from custody;
3. You are to 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;
4. You shall cooperate in the collection of a DNA sample;
5. Your travel is restricted to the Eastern, Northern, and Central Districts of California without the prior consent of the pretrial services officer;
6. You shall not possess a firearm/ammunition, destructive device, or other dangerous weapon; additionally, you shall provide written proof of divestment of all firearms/ammunition currently under your control;
7. You shall refrain from any use of alcohol or any use of a narcotic drug or other controlled substance without a prescription by a licensed medical practitioner; and you shall notify Pretrial Services immediately of any prescribed medication(s). However, medicinal marijuana, prescribed or not, may not be used;
8. You shall submit to drug and/or alcohol testing as approved by the pretrial services officer. You shall pay all or part of the costs of the testing services based upon your ability to pay, as determined by the pretrial services officer;
9. You shall surrender your passport to the Clerk, U. S. District Court, and obtain no passport during the pendency of this case;
10. You shall report any contact with law enforcement to your pretrial services officer within 24 hours;
11. You shall participate in the following home confinement program components and abide by all the requirements of the program, which will include electronic monitoring or other location verification system:
HOME DETENTION: You are restricted to your residence at all times except for employment; education; religious services; medical, substance abuse, or mental health treatment; attorney visits; court appearances; court-ordered obligations; or other activities pre-approved by the pretrial services officer.
You shall, in accordance with this release order, have a home monitoring unit installed in your residence, a radio frequency transmitter device attached to your person, and shall comply with all instructions for the use and operation of said devices as given to you by the Pretrial Services Agency and employees of the monitoring company. You shall pay all or part of the costs of the program based upon your ability to pay, as determined by the pretrial services officer;
12. You shall participate in a program of medical or psychiatric treatment, including treatment for drug or alcohol dependency, as approved by the pretrial services officer. You shall pay all or part of the costs of the counseling services based upon your ability to pay, as determined by the pretrial services officer; and,
13. You shall not associate or have any contact with any co-defendants unless in the presence of counsel or otherwise approved in advance by the pretrial services officer.
FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
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