Filed: Jun. 06, 2014
Latest Update: Jun. 06, 2014
Summary: STIPULATION BETWEEN THE PARTIES WITH PRE-TRIAL'S CONCURRENCE TO REMOVE SPECIAL CONDITIONS OF RELEASE # 11 AND 12 WITH ALL OTHER CONDITIONS TO REMAIN IN FULL FORCE AND EFFECT EDMUND F. BRENNAN, District Judge. The parties to this litigation, the United States of America, represented by Assistant United States Attorney, Jean Hobler and the defendant, KARI SONOVICH, represented by James R. Greiner, hereby stipulate and agree that Special Conditions of Release, paragraphs 11 and 12 (the location m
Summary: STIPULATION BETWEEN THE PARTIES WITH PRE-TRIAL'S CONCURRENCE TO REMOVE SPECIAL CONDITIONS OF RELEASE # 11 AND 12 WITH ALL OTHER CONDITIONS TO REMAIN IN FULL FORCE AND EFFECT EDMUND F. BRENNAN, District Judge. The parties to this litigation, the United States of America, represented by Assistant United States Attorney, Jean Hobler and the defendant, KARI SONOVICH, represented by James R. Greiner, hereby stipulate and agree that Special Conditions of Release, paragraphs 11 and 12 (the location mo..
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STIPULATION BETWEEN THE PARTIES WITH PRE-TRIAL'S CONCURRENCE TO REMOVE SPECIAL CONDITIONS OF RELEASE # 11 AND 12 WITH ALL OTHER CONDITIONS TO REMAIN IN FULL FORCE AND EFFECT
EDMUND F. BRENNAN, District Judge.
The parties to this litigation, the United States of America, represented by Assistant United States Attorney, Jean Hobler and the defendant, KARI SONOVICH, represented by James R. Greiner, hereby stipulate and agree that Special Conditions of Release, paragraphs 11 and 12 (the location monitoring program and the Curfew) can be removed from the defendant's Special Conditions of release.
Pre-Trial Services is in agreement with this agreement and stipulation of the parties.
The reasons supporting this stipulation and agreement of the parties, which Pre-Trial Services is in agreement with are as follows:
A. The defendant's overall compliance to conditions of release, and specifically to her electronically monitored curfew, since her release on supervision on 2/6/14. As such, the parties agree and Pre-Trial Services, who is charged with the monitoring and supervision of the defendant while on release conditions, agrees to remove conditions 11 and 12 which are:
Condition # 11. You shall participate in the following location monitoring program component and abide by all the requirements of the program, which will include having a location monitoring unit installed in your residence and a radio frequency transmitter device attached to your person. You 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; and
Condition # 12. CURFEW: You are restricted to your residence every day from 9pm to 6am, or as adjusted by the pretrial services officer for medical, religious services, employment or court ordered obligations.
Based upon the fact that Pretrial Services reviews all NON-MANDATED location monitoring supervision cases every 90 days to determine if
1 — the condition is still warranted,
2 — based on risk factors,
3 — compliance to conditions,
4 — defendant's stability,
5 — and all other relevant factors of supervision in the case of each specific defendant, in this particular and specific case, of defendant Kari Sonovich, based on all of the factors listed and the totality of Pre-Trial Services supervision, it was determined it would be appropriate to remove electronic monitoring and curfew for Ms. Sonovich.
The parties also agree and stipulate that all other conditions of release, including all of the other Special Conditions of release, shall remain in full force and effect. Pre-Trial Services is also in agreement with this agreement and stipulation of the parties.
[PROPOSED] ORDER
FOR GOOD CAUSE SHOWN,
Paragraphs 11 and 12 under the Special Conditions of Release are hereby removed and vacated with all other conditions of release, including all other Special Conditions of Release, to remain in full force and effect.
IT IS SO FOUND AND ORDERED.
