STIPULATION for Modification of Conditions of Release filed by Defendant Hassan Kanyike — USA v. Kanyike (Dkt. 17)

Record facts

U.S. District Court for the Central District of California · No. 2:20-mj-05936-DUTY · Doc. 17 · 2020-12-22 · Docket on CourtListener

Summary

A stipulation regarding defendant's bond and conditions of release, filed December 22, 2020 as Document 17 in United States of America v. Hassan Kanyike, No. 2:20-mj-05936-DUTY, in the U.S. District Court for the Central District of California. Assistant United States Attorney Richard E. Robinson and defense counsel Victor Sherman recommend a total bond of $170,000, supported by five sureties' affidavits of $20,000 each and a $70,000 appearance bond by the defendant, to be secured by his real property by January 11, 2021. The proposed conditions include Pretrial Services supervision, surrender of passports within 72 hours, travel restricted to the Central District of California, a nightly curfew, location monitoring without a bracelet, and no contact with known victims or witnesses. The stipulation is dated December 21, 2020 and asks the Court to issue a Form CR-1 release order.

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Full text

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1 
 
 
 
VICTOR SHERMAN (SBN 38483) 
LAW OFFICES OF VICTOR SHERMAN 
11400 West Olympic Boulevard, Suite 1500 
Los Angeles, California 90064 
Telephone (424) 371-5930 
Facsimile (310) 392-9029 
Email: victor@victorsherman.law 
 
Attorney for Defendant 
HASSAN KANYIKE 
 
 
 
UNITED STATES DISTRICT COURT 
 
FOR THE CENTRAL DISTRICT OF CALIFORNIA 
 
UNITED STATES OF AMERICA, 
 
Plaintiff, 
 
v. 
 
HASSAN KANYIKE, 
  
Defendant. 
 
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Case No.  20-MJ-05936 
 
STIPULATION RE 
DEFENDANT’S BOND AND 
CONDITIONS OF RELEASE 
 
 
 
Plaintiff United States of America, by and through its counsel of record, 
United States Attorney Nicolas T. Hanna and Assistant United States Attorney 
Richard E. Robinson, and defendant HASSAN KANYIKE (“Defendant”), by and 
through his counsel of record, VICTOR SHERMAN, hereby stipulate and 
recommend that the bond and conditions of release in this matter be set as follows: 
1. 
Total bond is in the sum of $170,000.  The bond will be supported by 
Affidavits of Surety (No Justification) executed by Najjemba Annet Muwanga for 
$20,000; by Wasswa Umar Kintu for $20,000; by Emmanuel Kibukamusoke for 
$20,000; by Frank Katende for $20,000, and by Terence Kibukamusoke for $20,000; 
and an unsecured appearance bond in the amount of $70,000 by Defendant.  
Case 2:20-mj-05936-DUTY     Document 17     Filed 12/22/20     Page 1 of 4   Page ID #:59

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2 
 
 
 
Defendant has provided identifying information for each of the sureties to the 
government.   
2. 
By no later than January 11, 2021, Defendant will replace Defendant’s 
unsecured $70,000 appearance bond with a secured bond executed by Defendant in 
the amount of $70,000, which is secured by full deeding of Defendant’s real property 
located at 19845 Ellis Henry Ct., Newhall, California 91321-2185 (the “Property”).  
Defendant represents that he is sole owner of the Property and that it has a current 
appraised value of approximately $705,000, with a mortgage balance of 
approximately $593,000. 
3. 
Defendant will submit to Pretrial Services Agency (“PSA”) supervision 
as directed by PSA.  
4. 
Defendant will surrender all passports and travel documents to PSA 
within 72 hours of his release, sign a declaration regarding passport and other travel 
documents, and not apply for a passport or other travel documents during the 
pendency of this case.   
5. 
Defendant’s travel is restricted to the Central District of California. 
6. 
Defendant will reside at the Property, as approved by PSA, and will not 
relocate without prior permission of PSA.  Defendant is restricted to his approved 
residence every day from 10 p.m. to 6 a.m., unless otherwise directed by PSA. 
7. 
Defendant will comply with local, state, and federal guidelines re: 
COVID-19.   
8. 
Defendant will participate in the Location Monitoring Program and 
abide by all of the requirements of the program, under the direction of PSA, which 
will not include a location monitoring bracelet.  Defendant will pay all or part of the 
costs of the program based upon Defendant’s ability to pay as determined by PSA.  
Defendant will be financially responsible for any lost or damaged equipment.   
Case 2:20-mj-05936-DUTY     Document 17     Filed 12/22/20     Page 2 of 4   Page ID #:60

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9. 
Defendant will avoid all contact, directly or indirectly (including by any 
electronic means), with any person who is a known victim or witness in the subject 
investigation or prosecution.  Notwithstanding this provision, Defendant may have 
contact with the following individuals while they are living with Defendant at the 
Property: Joseph Muhumuza, Robert Lubega, Hamidu Wassaja, and Priscilla Nakato.  
Defendant, however, will not to discuss anything to do with the subject investigation 
or prosecution with any of said individuals, except in the presence of Defendant’s 
counsel.   
10. 
Defendant will not: 
a. 
possess any firearms, ammunition, destructive devices, or other 
dangerous weapons.  In order to determine compliance, Defendant agrees to submit 
to search of his person and/or property by PSA in conjunction with the U.S. Marshal.   
b. 
use or possess any identification, mail matter, access device, or 
any identification-related material other than in Defendant’s own legal or true name 
without prior permission from PSA.  In order to determine compliance, Defendant 
agrees to submit to search of his person and/or property by PSA in conjunction with 
the U.S. Marshal.   
c. 
sell, transfer, or give away any asset valued at $1,000 or more 
without notifying and obtaining permission from the Court. This provision also 
applies to the following businesses: “Falcon Motors Inc.” and “HK Developments 
International” or “HK Development International.” 
11. 
Within 24 hours of his release, Defendant will meet (virtually, if 
appropriate) with his counsel and PSA to go over the terms of his release.   
12. 
The parties request that the Court issue a Release Order and Bond Form 
(Form CR-1), which includes the above additional conditions and standard general 
conditions of release, and such other conditions as the Court deems appropriate.  
Case 2:20-mj-05936-DUTY     Document 17     Filed 12/22/20     Page 3 of 4   Page ID #:61

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4 
 
 
 
Within 24 hours of Defendant’s meeting with PSA described in paragraph 11, 
Defendant’s counsel will file the Form CR-1 signed by Defendant.     
13. 
Within 48 hours of Defendant’s release, Defendant’s counsel will 
contact the Court’s courtroom deputy to schedule a VTC hearing for the Court to 
address Defendant concerning the conditions of Defendant’s release.    
 
 
 
 
 
 
Dated: December 21, 2020 
 
 
Respectfully submitted, 
 
 
      
 
 
 
 
 
 
 
/s/ Richard E. Robinson___________ 
 
 
 
 
 
 
 
RICHARD E. ROBINSON 
 
 
 
 
 
 
 
Assistant United States Attorney 
 
  
 
 
Dated: December 21, 2020 
     
 
/s/ Victor Sherman_________ 
VICTOR SHERMAN 
Attorney for Defendant 
HASSAN KANYIKE 
Case 2:20-mj-05936-DUTY     Document 17     Filed 12/22/20     Page 4 of 4   Page ID #:62

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