Case 2:14-cr-00262-JLR Document 27 Filed 12/17/14 Page 1 of 4

Honorable Mary Alice Theiler

1
2
3
4
5
6

UNITED STATES DISTRICT COURT FOR THE

WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

7
8
9
10

UNITED STATES OF AMERICA,

11

Plaintiff

12
13

v.
KESHAV MUKUND BHIDE,

14

CASE NO. CR14-262-JLR

AGREED MOTION TO MODIFY
CONDITIONS IN DEFENDANTS
APPEARANCE BOND

Defendant.
Noting Date: December 15, 2014

15
16
17

On June 18, 2014, a Complaint was filed in the United States District Court for the

18 Western District of Washington charging Defendant Keshav Bhide with making interstate
19 threats in violation of 18 U.S.C. 875(c), and Chief Magistrate Judge Mary Alice Theiler
20 issued a warrant for Defendants arrest.
21

At a detention hearing on June 26, 2014, Defendant was released from custody

22 subject to the conditions set forth in an Appearance Bond that remains in place today.
23 These conditions include: (1) that Defendant shall participate in the location monitoring
24 program with Active Global Positioning Satellite technology; and (2) that Defendant
25 must surrender his passport and travel documents to the Court. See Appearance Bond
26 filed in Case No. 14-MJ-245-MAT, at Dkt. No. 12.
27 //
28
AGREED MOTION TO MODIFY CONDITIONS IN DEFENDANTS
APPEARANCE BOND - 1

UNITED STATES ATTORNEY

700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

Case 2:14-cr-00262-JLR Document 27 Filed 12/17/14 Page 2 of 4

On September 17, 2014, the Grand Jury issued an Indictment charging Defendant

2 with the interstate transmittal of threats to cause serious physical injury or death to
3 women, in violation of 18 U.S.C. 875(c).
The parties have now agreed on a resolution that will ultimately lead to the

5 Governments request to dismiss the currently pending charges without prejudice.

6 Pursuant to the parties agreement:
Defendant has pleaded guilty in King County Superior Court to the state
charge of cyberstalking, in violation of RCW 9.61.260, and been sentenced to a
six month suspended sentence.

7
8
9

Defendant has stipulated to the allegations set forth in a Notice to Appear

issued by the Department of Homeland Security, United States Immigration
and Customs Enforcement (ICE). Before December 24, 2014, Defendant
will be ordered removed from the United States by agreement.

10
11
12

Defendant has signed an agreement tolling the statute of limitations for the
currently pending federal charges for a period of five years, such that the
statute of limitations is now ten years.

13
14
15

After coordinating with counsel for the Government and ICE, Defendant has
purchased a plane ticket to return to India on December 24, 2014.

16
17

On December 24, 2014, Special Agents from Homeland Security

Investigations (HSI) and/or the FBI will pick up Defendant at his residence and
bring him to the Federal Courthouse in Seattle for the removal of his location
monitoring equipment, after which they will transport him to the airport and
escort him to his flight.

18
19
20
21

After Defendant departs the United States, the Government will move to
dismiss the pending federal charges with prejudice, with the understanding that
if Defendant reenters or attempts to reenter the United States before the
expiration of the statute of limitations, the Government may refile the charges.

22
23
24

//

25
26
27
28
AGREED MOTION TO MODIFY CONDITIONS IN DEFENDANTS
APPEARANCE BOND - 2

UNITED STATES ATTORNEY

700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

Case 2:14-cr-00262-JLR Document 27 Filed 12/17/14 Page 3 of 4

In order to effectuate the resolution discussed above, Defendant would need to be

2 terminated from the location monitoring program and to obtain his Indian passport from
3 the Court prior to his departure on December 24, 2014, both of which require a
4 modification to the terms in the Appearance Bond. Accordingly, the parties to the above5 referenced action hereby jointly and respectfully request the Court to issue an order
6 modifying the terms of the Appearance Bond to (1) terminate Defendants participation
7 in location monitoring as of December 24, 2014, and (2) order that Defendants passport
8 shall be provided to HSI SA Tom Skalski, prior to Defendants departure on December
9 24, 2014.
Officer Lonnie Kamen from Pretrial Services has been consulted about this

10

11 Motion and has no objection. In addition, Officer Kaman will assist in facilitating the
12 resolution discussed above by granting Defendant the necessary permissions under the
13 terms of the Appearance Bond (such as permitting him to leave the Country on December
14 24).
15

DATED this 17th day of December, 2014.

16
17

s/ Rebecca S. Cohen
18 REBECCA S. COHEN
Assistant United States Attorney
19
United States Attorneys Office
20

s/ Peter J. Avenia
PETER J. AVENIA
Assistant Federal Public Defender
Attorney for Keshav Bhide

21
22
23
24
25
26
27
28
AGREED MOTION TO MODIFY CONDITIONS IN DEFENDANTS
APPEARANCE BOND - 3

UNITED STATES ATTORNEY

700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970

Case 2:14-cr-00262-JLR Document 27 Filed 12/17/14 Page 4 of 4

1
2

CERTIFICATE OF SERVICE
I hereby certify that on December 17, 2014, I electronically filed the foregoing

3 with the Clerk of the Court using the CM/ECF system which will send notification of
4 such filing to the attorney(s) of record for the defendant(s).
5
6
7
8
9
10

s/ Katelyn R. Mitchell
KATELYN R. MITCHELL
Paralegal Specialist
United States Attorneys Office
700 Stewart Street, Suite 5220
Seattle, Washington 98101-1271
Telephone: 206-553-4161
Fax: 206-553-0882
Email: katelyn.mitchell@usdoj.gov

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
AGREED MOTION TO MODIFY CONDITIONS IN DEFENDANTS
APPEARANCE BOND - 4

UNITED STATES ATTORNEY

700 STEWART STREET, SUITE 5220
SEATTLE, WASHINGTON 98101
(206) 553-7970