Filed: Nov. 15, 2018
Latest Update: Nov. 15, 2018
Summary: STIPULATION REGARDING MODIFICATION OF RELEASE CONDITIONS; FINDINGS AND ORDER GARLAND E. BURRELL, JR. , Senior District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through Defendant's counsel of record, hereby stipulate as follows: 1. Defendant has lost his job as an Uber/Lift driver after his employers, Uber and Lift, found out about this case. Defendant has not been successful in securing other employment but for one
Summary: STIPULATION REGARDING MODIFICATION OF RELEASE CONDITIONS; FINDINGS AND ORDER GARLAND E. BURRELL, JR. , Senior District Judge . STIPULATION Plaintiff United States of America, by and through its counsel of record, and defendant, by and through Defendant's counsel of record, hereby stipulate as follows: 1. Defendant has lost his job as an Uber/Lift driver after his employers, Uber and Lift, found out about this case. Defendant has not been successful in securing other employment but for one ..
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STIPULATION REGARDING MODIFICATION OF RELEASE CONDITIONS; FINDINGS AND ORDER
GARLAND E. BURRELL, JR., Senior District Judge.
STIPULATION
Plaintiff United States of America, by and through its counsel of record, and defendant, by and through Defendant's counsel of record, hereby stipulate as follows:
1. Defendant has lost his job as an Uber/Lift driver after his employers, Uber and Lift, found out about this case. Defendant has not been successful in securing other employment but for one that requires him to travel to other states as a sales person for a distribution company selling various types of clothing. Defendant will be traveling to various trade shows and stores offering these products.
2. Both the Government and Pretrial services have no objection to said employment and have agreed that the location monitoring/curfew conditions for the Defendant are to be removed. Any travel requests for employment, however, would still have to be approved in advance by Pretrial Services. Even with the removal of the conditions Defendant Akhmerov would still have to submit his flight/hotel/employment proof prior to his travel.
3. Defendant Akhmerov will have to adhere to the following conditions:
a) You must report to and comply with the rules and regulations of the Pretrial Services Agency;
b) You must report in person to the Pretrial Services Agency on the first working day following your release from custody;
c) You must 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;
d) You must cooperate in the collection of a DNA sample;
e) You must restrict your travel to the Central and Eastern Districts of California unless otherwise approved in advance by the pretrial services officer;
f) You must surrender your passport and not obtain a passport or other travel documents during the pendency of this case;
g) You must not possess, have in your residence, or have access to a firearm/ammunition, destructive device, or other dangerous weapon; additionally, you must provide written proof of divestment of all firearms/ammunition currently under your control;
h) You must seek and/or maintain employment and provide proof of same as requested by your pretrial services officer;
i) You must report any contact with law enforcement to your pretrial services officer within 24 hours;
j) You must not associate or have any contact with co-defendants unless in the presence of counsel or otherwise approved in advance by the pretrial services officer;
k) You must not use or possess access devices/credit cards in any name other than your true name.
4. Counsel for defendant believes that failure to grant the above-requested modifications would deny Defendant the ability to financially sustain himself while out of custody. In fact, Defendant does not have any funds to pay rent and is looking to borrow this sum. Securing this employment is critical.
IT IS SO STIPULATED.
FINDINGS AND ORDER
IT IS SO FOUND AND ORDERED.
