UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
v. : CRIMINAL NO. xx-444M-01 (DAR)
xxxxxxxxxxxxxxx :
MOTION FOR ONE-DAY MODIFICATION OF CONDITIONS OF RELEASE
xxxxxxxxxx, through undersigned counsel, hereby moves this Honorable Court for a one-day modification of her conditions of release to allow her to retrieve her property and personal belongings from xxxxxxxxxxx, N.E. and put them into storage prior to July 31, 1993.
In support of this motion, Ms. xxxxxxxx, through undersigned counsel submits:
On July 7, 1993 Ms. xxxxxxxx was presented on a complaint in this matter and released to her brother's third-party custody to live with him at xxxxxxxxxxxxx, Apt. xxx, Lanham, Maryland. Among Ms. xxxxxxxx's conditions of release was that she stay away from the xxxx block of Faraday Place, N.E., which is where her residence was located and where the search warrant in this case was executed.
Ms. xxxxxxxx needs to return to her previous residence before July 31, 1993 to retrieve her belongings and personal property so that she can put them into storage and avoid losing everything she owns. On July 27, 1993 undersigned counsel spoke with the Assistant United States Attorney who is handling this matter, Denise Abrahams, and she indicated that the government would take no position on the requested one-day modification of Ms. xxxxxxxx's release conditions.
WHEREFORE, for these reasons and other such reasons as shall appear to
the Court, Ms. xxxxxxxx requests that this Motion be granted and that her conditions of
release be modified to excuse, for one day only and prior to July 31, 1993,,
the prohibition on Ms. xxxxxxxx entering the xxx block of Faraday Place, N.E.
Respectfully submitted,
A. J. KRAMER
FEDERAL PUBLIC DEFENDER
Santha Sonenberg
Assistant Federal Public Defender
On Behalf of xxxxxxxx
625 Indiana Avenue, NW Suite 550
Washington, DC 20004
(202) 208-7500
CERTIFICATE OF SERVICE
This is to certify that a copy of the foregoing Motion For One-Day Modification of
Conditions of Release has been served upon the Office of the United States Attorney, 555
Fourth Street, N.W., Washington, D.C. 20001 by hand by leaving a copy in the box
designated for the Office of the United States Attorney located in the Clerk's Office of
the United States District Court for the District of Columbia this 28th day of July, 1993
for Assistant United States Attorney Denise Abrahams.
Santha Sonenberg
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
UNITED STATES OF AMERICA :
v. : CRIMINAL NO. xx-444M-01 (DAR)
xxxxxxxx :
O R D E R
Upon consideration of the Motion For One-Day Modification of Conditions Of Release
filed herein on July 28, 1993, it is this day of July, 1993, HEREBY ORDERED
that Ms. xxxxxxxx's motion is granted and she is permitted to go to xxx Faraday Place,
N.E. for one day prior to July 31, 1993 to move her belongings and personal property out
and put them into storage.
Deborah A. Robinson
United States Magistrate Judge
Copies To:
Santha Sonenberg
Office of the Federal Public Defender
625 Indiana Avenue, N.W.
Washington, D.C. 20004
Janice Bergin
District of Columbia Pretrial Services Agency
United States Courthouse
Washington, D.C. 20001
Denise Abrahams
Office of the United States Attorney
555 Fourth Street, N.W.
Washington, D.C. 20001