Filed: Nov. 16, 2015
Latest Update: Nov. 16, 2015
Summary: MOTION FOR BAIL REVIEW; PROPOSED STIPULATED CONDITIONS OF RELEASE; DECLARATION OF EDWARD M. ROBINSON; EXHIBIT IN SUPPORT; ORDER ANTHONY W. ISHII , Senior District Judge . Defendant Zaid Elodat ("Mr. Elodat") by and through his attorney of record Edward M. Robinson, hereby gives notice of motion and motion for bail review to be set before this Court on November 17, 2015 at 10:00 a.m. This motion is based upon the attached stipulated terms and conditions of release and the new information to
Summary: MOTION FOR BAIL REVIEW; PROPOSED STIPULATED CONDITIONS OF RELEASE; DECLARATION OF EDWARD M. ROBINSON; EXHIBIT IN SUPPORT; ORDER ANTHONY W. ISHII , Senior District Judge . Defendant Zaid Elodat ("Mr. Elodat") by and through his attorney of record Edward M. Robinson, hereby gives notice of motion and motion for bail review to be set before this Court on November 17, 2015 at 10:00 a.m. This motion is based upon the attached stipulated terms and conditions of release and the new information to ..
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MOTION FOR BAIL REVIEW; PROPOSED STIPULATED CONDITIONS OF RELEASE; DECLARATION OF EDWARD M. ROBINSON; EXHIBIT IN SUPPORT; ORDER
ANTHONY W. ISHII, Senior District Judge.
Defendant Zaid Elodat ("Mr. Elodat") by and through his attorney of record Edward M. Robinson, hereby gives notice of motion and motion for bail review to be set before this Court on November 17, 2015 at 10:00 a.m.
This motion is based upon the attached stipulated terms and conditions of release and the new information to include the posting of a $20,000.00, cash bond in lieu of the property bond considered by the parties. (Exhibit "A")
Furthermore, counsel for Mr. Elodat requests permission by this court to appear telephonically on November 17, 2015 at 10:00 a.m.
DECLARATION OF EDWARD M. ROBINSON
I, EDWARD M. ROBINSON, declare:
That I am attorney of record for Zaid Elodat in the above referenced matter.
1. That on October 14, 2015, Mr. Elodat appeared in the United States District Court — Central District of California. At that hearing, Magistrate Charles F. Eick ordered Mr. Elodat released on a $25,000.00, unsecured bond.
2. That The U.S. Attorney's office for the Eastern District of California, through Karen A. Escobar applied to this Court and received a stay of Magistrate Judge Eick's release order pending a hearing in the Eastern District.
3. The parties have agreed that Mr. Elodat, subject to this Court's order, be released on the special conditions of release attached hereto as Exhibit "A." These proposed conditions of release are based upon Mr. Elodat's father's willingness to post $20,000.00 cash as security. The parties agree that this additional security along with the special conditions set forth in Exhibit "A" will ensure Mr. Elodat's appearance and protect the public.
4. Furthermore, counsel for Mr. Elodat has requested permission to appear telephonically.
Executed this 16th day of November 2015, in the City of Torrance, State of California.
ORDER
GOOD CAUSE HAVING BEEN SHOWN, Defendant Zaid Elodat shall be on calendar for bail review before this Court on November 17, 2015 at 10:00 a.m. Furthermore, counsel for Defendant shall appear telephonically.
IT IS SO ORDERED.
EXHIBIT "A"
SPECIAL CONDITIONS OF RELEASE
Re: ELODAT, Zaid
No.: 1:15cr286-AWI-BAM-2
Date:November 13, 2015
1. You shall be released on a $20,000 cash bond, posted by the defendant's family;
2. You shall report to and comply with the rules and regulations of the Pretrial Services Agency;
3. You shall report in person to the Pretrial Services Agency on the first working day following your release from custody;
4. 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;
5. You shall cooperate in the collection of a DNA sample;
6. Your travel is restricted to Eastern and the Central Districts of California unless otherwise approved in advance by the pretrial services officer;
7. You shall surrender your passport to the Clerk, U. S. District Court, and obtain no passport during the pendency of this case;
8. 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;
9. You shall refrain from excessive 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;
10. 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;
11. 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;
12. You shall 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; and,
13. You shall report any contact with law enforcement to your pretrial services officer within 24 hours;
