STIPULATION AND ORDER FOR TEMPORARY RELEASE TO ATTEND FUNERAL SERVICES

CAROLYN K. DELANEY, Magistrate Judge.

Defendant ROBERT LARRY MOORE by and through his counsel, TASHA PARIS CHALFANT, and the United States Government, by and through its counsel, OLUSERE OLOWOYEYE, Assistant United States Attorney, hereby stipulate to the following:

It has been agreed by all parties for a temporary release of Mr. MOORE from Thursday, September 18, 2014 at 8:00 a.m. to Tuesday, September 23, 2014 by 2:00 p.m., to attend the funeral and burial of ashes for his son, ROBERT LARRY MOORE, JR. Mr. MOORE, SR. is currently in custody at the Sacramento County Jail pending charges in the above case; the matter is next scheduled for October 9, 2014, for Status Conference.

Mr. MOORE JR. passed away on September 7, 2014, after being admitted to the hospital on September 3, 2014. Mr. MOORE JR. was partially disabled and wheelchair bound, but he unexpectedly passed away from liver and kidney failure. The funeral is scheduled for Friday, September 19, 2014, between 6:00 p.m. to 8:00 p.m. at Blevins Funeral Home, located at 417 Lee Street, Bristol, Virginia 24201. The private ceremony for burial of ashes is on Saturday, September 20, 2014, at 2:00 p.m. at the Shipley Cemetery, located at 412 Hayes Road, Bluff City, Tennessee 37620.

The government does not oppose this request. Counsel for the government agree and stipulate that Mr. MOORE be released from the Sacramento County Main Jail on Thursday, September 18, 2014, to the custody of the US Marshals during the morning transport to the US Marshals office on the 5th floor of the Federal Building. Investigator, Frank W. Huntington, III, will pick up Mr. MOORE from the US Marshals office at 8:00 a.m. and deliver him to the Sacramento International Airport (SMF) for his flight to Tri Cities, Tennessee Airport (TRI). The family has shopped the various flights available for Mr. Moore and will purchase the tickets once this order is signed. It seems that depending on the airline chosen, the travel time will be between 8-11 hours (which is why it seems necessary to have him travel the day before the actual funeral service).

Upon arrival in Tennessee, Ms. January Rush, who is Mr. MOORE's adult daughter, will supervise and act as a third party custodian during the transport from the airport, to his home, funeral service and burial at the cemetery until Mr. MOORE'S return to Sacramento. On Monday, September 21, 2014, Ms. January Rush will deliver Mr. MOORE to the Tri Cities, Tennessee Airport (TRI) for his return flight to the Sacramento International Airport (SMF). Investigator Frank W. Huntington III, will pick up Mr. MOORE from the Sacramento International Airport (SMF) and deliver him to the US Marshals office on the 5th floor of the Federal Building before 2:00 p.m. on Tuesday, September 22, 2014. The US Marshals will then return Mr. MOORE to the Sacramento Main Jail during their afternoon transport.

Therefore, attorney TASHA PARIS CHALFANT, has arranged for investigator Frank W. Huntington III and January Rush, to execute the above described responsibilities. Mr. Moore is currently in custody for violating his conditions of pretrial release by committing a new law violation and for failing to report contact with law enforcement within 24 hours to Pretrial Services.

Pretrial Services has confirmed the passing of the defendant's son. Pretrial Services has contacted the defendant's daughter, January Rush, who has agreed to remain with the defendant at all times and act as a temporary third-party custodian during this period of release. Ms. Rush has agreed to assist with his supervision and report any known violations to Pretrial Services during this time period.

Pretrial Services has also confirmed the defendant will be transported to and from the Sacramento International Airport by Investigator, Frank W. Huntington, III.

Please note, Pretrial Services does not have the capability of electronically monitoring the defendant during this travel period.

Considering Mr. Moore is currently in custody as a result of violating his conditions of release, Pretrial Services will defer to the Court on whether this travel should be authorized.

Mr. MOORE will remain in the custody of either Frank W. Huntington III or January Rush during the entire time of his release. They each agree to keep strict control over Mr. MOORE at all times.

For the above reasons, Defendant ROBERT LARRY MOORE, Sr., respectfully requests that the Court allow this temporary release.

IT IS SO ORDERED.