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United States v. Bushnell

United States District Court, Ninth Circuit

May 8, 2013

UNITED STATES OF AMERICA, Plaintiff,
v.
RANDALL EDWARD BUSHNELL, Defendant.

STEVEN G. KALAR, Federal Public Defender, ELIZABETH M. FALK, Assistant Federal Public Defender, San Francisco, CA, STACEY GEIS, ASSISTANT UNITED STATES ATTORNEY. Counsel for Defendant BUSHNELL.

STIPULATION AND [PROPOSED] ORDER TEMPORARILY MODIFYING IN-DISTRICT BOND CONDITIONS Court:

LAUREL BEELER, District Judge.

The parties hereby stipulate and agree as follows:

1. Defendant Randall Bushnell hereby requests permission to temporarily modify his bond conditions for the purpose of moving some of his belongings to his mother's house in Los Angeles prior to surrendering for a custodial sentence;
2. Defendant Randall Bushnell thus requests this Court to modify the bond condition requiring him to remain in the Northern District of California between May 8, 2013 and May 13, 2013 to allow for travel to the Central District of California. Specifically, Mr. Bushnell requests permission to leave the district by car on Wednesday, May 8, 2013 - to drive to Los Angeles, California and reside for the nights of May 8, 2013 through May 12, 2013, 2013 at the home of his mother, Sandra Bushnell, at 5757 Ravenspur Road in Los Angeles, CA, 90274. He would return to this district Monday, May 13, 2013;
3. In so requesting a stay of that bond condition, defendant Randall Bushnell hereby attests that he will 1) provide Pretrial Services with an exact itinerary of his trip, including the method and mode of transportation; 2) keep in telephone contact with U.S. Pretrial Services on a daily basis while out of the district, and provide all location and contact information daily, and 3) cooperate with Pretrial Services by providing any and all additional information requested by that agency regarding his travel plans, travel locations, and contact information while traveling;
4. United States Pretrial Services Officer Gelareh Farahmand has been consulted regarding this stipulation. She has no objection to the proposed modification provided that the defendant promises to comply and does comply with the aforementioned conditions stated in Paragraph 3, above;
5. The government has also been consulted about this request. As indicated by the signature below, there is no opposition to the proposed modification of pre-surrender bond terms.

IT IS SO STIPULATED.

[PROPOSED] ORDER

For the reasons set forth above, the bond conditions of Randall Bushnell are hereby modified between May 8, 2013 and May 13, 2013 as follows:

1. The condition requiring the defendant to remain in the Northern District of California is hereby MODIFIED to include and allow travel within the Central District of California on between May 8 and May 13, 2013;

2. Defendant Randall Bushnell is required, as a condition of this modification, to 1) provide Pretrial Services with an itinerary of his trip, including the method and mode of transportation, proposed dates of travel, and the locations he anticipates visiting, 2) keep in telephone contact with U.S. Pretrial Services on a daily basis while out of the district, and provide all location and contact information daily, and 3) cooperate with Pretrial Services by providing any and all additional information requested by that agency regarding his travel plans, travel locations, and contact information while traveling;

3. This modification of bond conditions will terminate on May 13, 2013.

IT IS SO ORDERED.


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