Opinion
No. CR 13-226 CRB
04-24-2013
UNITED STATES OF AMERICA, Plaintiff, v. ADAM RAYBOURN, Defendant.
STEVEN G. KALAR Federal Public Defender ELIZABETH M. FALK Assistant Federal Public Defender Counsel for Defendant RAYBOURN
STEVEN G. KALAR
Federal Public Defender
ELIZABETH M. FALK
Assistant Federal Public Defender
Counsel for Defendant RAYBOURN
STIPULATION AND [PROPOSED]
ORDER MODIFYING IN-DISTRICT
BOND CONDITIONS
Court: The Honorable Laurel Beeler
The parties hereby stipulate and agree as follows:
1. Defendant Adam Raybourn hereby requests a modification his bond conditions for the purpose of work. He is currently employed in the wine delivery business in Napa and his responsibilities entail driving trucks to Sacramento and the surrounding areas;IT IS SO STIPULATED.
2. Defendant Adam Reybourn thus requests this Court to modify the bond condition requiring him to remain in the Northern District of California, to allow for travel to the Eastern District of California.;
3. United States Pretrial Services Officer Allen Lew has been consulted regarding this stipulation. He has no objection to the proposed modification extending the
travel restriction to the Eastern District of California;
4. The government has also been consulted about this request. As indicated by the signature below, there is no opposition to the proposed modification.
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ELIZABETH M. FALK
ASSISTANT FEDERAL PUBLIC DEFENDER
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PHILIP KEARNEY
ASSISTANT UNITED STATES ATTORNEY
[PROPOSED] ORDER
For the reasons set forth above, the bond conditions of Adam Raybourn are hereby modified 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 Eastern District of California.
IT IS SO ORDERED.
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THE HONORABLE LAUREL PEELER
UNITED STATES MAGISTRATE JUDGE
Nandor J. Vadas
United States Magistrate Judge