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BARRY J. PORTMAN

Federal Public Defender

LOREN D. STEWART

Assistant Federal Public Defender

19th Floor Federal Building – Box 36106

450 Golden Gate Avenue

San Francisco, CA 94102

Telephone: (415) 436-7700

Counsel for Defendant TRABULSE

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

UNITED STATES OF AMERICA,

Plaintiff,

vs.

ALEXANDER JAMES TRABULSE,

Defendant.

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No. CR-09-0350 WHA / EDL

STIPULATION AND [PROPOSED]

ORDER MODIFYING CONDITIONS OF

RELEASE FOR SELF-SURRENDER

On January 9, 2009, this Court imposed conditions of release on the Defendant,

Alexander James Trabulse, that includes a restriction of strict home confinement, monitored with

an electronic monitoring device. Initially Mr. Trabulse was compelled to remain home 24 hours

per day, 7 days per week, except for Court appearances, legal visits, attendance of religious

services, and medical emergencies. On May 6, 2009, the Court modified the conditions such that

Mr. Trabulse is permitted to leave home Monday through Friday from 1:00 PM to 4:00 PM. 

See Docket No. 33. Apart from attendance of religious services, Mr. Trabulse has been unable to

leave his home on weekends.

On May 3, 2010, the Honorable William H. Alsup sentenced Mr. Trabulse to a term of

imprisonment of 97 months. See Docket No. 90. Mr. Trabulse was permitted to surrender

STIP & [PROPOSED] ORDER RE: SELFSURRENDER, CR-09-0350 WHA 1

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directly to the designated Bureau of Prisons institution within 90 days of the sentencing, or by

August 3, 2010, at 12:00 PM. See id. Mr. Trabulse has been informed by the U.S. Marshals

Service, through undersigned counsel, that he is to surrender directly to FCI Sheridan, a federal

prison in Oregon that is approximately 650 miles from Mr. Trabulse’s home in Daly City,

California. 

With his surrender only a matter of weeks away, Mr. Trabulse respectfully requests the

following modifications to his conditions of pretrial release to facilitate the moving and storing

of his personal effects and the lengthy trip to Sheridan, Oregon.

1. Mr. Trabulse requests that he be permitted to leave his home from 8:30 AM to

6:00 PM on Saturday, July 24, 2010, and from 8:30 AM to 6:00 PM on Saturday,

July 31, 2010. On those dates he will, with the help of family members, move his

personal effects from his rental home into storage at his daughter’s home.

2. Mr. Trabulse requests that he be permitted to depart from Daly City on Sunday,

August 1, 2010, at 9:00 AM to drive to Sheridan, Oregon. He intends to complete

the 650-mile drive over the course of two days—August 1 and August 2—to

arrive in Sheridan on the evening of August 2 and be prepared to surrender on the

morning of August 3, as ordered.

Mr. Trabulse has been informed by his Pretrial Services Officer that he is to surrender the

electronic monitoring device before he departs for FCI Sheridan. Mr. Trabulse asks that he be

permitted to return the electronic monitoring device on his departure, as directed by Pretrial

Services.

Undersigned counsel for Mr. Trabulse has communicated with U.S. Pretrial Services

Officer Richard Sarlatte and confirmed that Mr. Sarlatte has no objection to the proposed course

of action. Officer Sarlatte or another Pretrial Services Officer will coordinate Mr. Trabulse’s

departure for FCI Sheridan and the return of the electronic monitoring device.

STIP & [PROPOSED] ORDER RE: SELFSURRENDER, CR-09-0350 WHA 2

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IT IS SO STIPULATED.

DATED: July 22, 2010 /s/ 

Jonathan Schmidt

Assistant United States Attorney

DATED: July 22, 2010 /s/ 

Loren D. Stewart

Assistant Federal Public Defender

[PROPOSED] ORDER

For the foregoing reasons, the Court hereby ORDERS that the Defendant, Alexander

James Trabulse, shall be permitted to leave home for purposes of moving his personal effects on

July 24, 2010, from 8:30 AM to 6:00 PM, and again on July 31, 2010, from 8:30 AM to 6:00

PM. He shall also be permitted to depart for FCI Sheridan on August 1, 2010, at 9:00 AM, and

arrange for the return of the electronic monitoring device at that time. All other conditions of

pretrial release shall remain in full effect.

IT IS SO ORDERED.

Dated: 

Hon. Elizabeth Laporte

United States Magistrate Judge

STIP & [PROPOSED] ORDER RE: SELFSURRENDER, CR-09-0350 WHA 3

July 22, 2010

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge Elizabeth D. Laporte

Case 3:09-cr-00350-WHA Document 99 Filed 07/23/10 Page 3 of 3