Free Redacted Document - District Court of Delaware - Delaware

Case 1:07-cr—OOO26-SLR Document 13 Filed O3/30/2007 Page 1 of 4
Case 1:07-cr-00026-SLQ.`) epl\1/2,\lj(Ei`,ed_|‘,i§§’»O!2007 Page 1 of 3
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IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Plaintiff
v. Criminal Action No. 07-26-SLR
EARL WALLACE,
Defendant.
MOTION FOR MODIFICATION OF RESIDENCE
Defendant, Earl Wallace, by and through his undersigned counsel, Eleni Kousoulis, hereby
moves the Court for an order modifying his place of residence. In support ofthe motion, the defense
submits as follows:
l. On February 28, 2007, Mr. Wallace was ordered by Magistrate Judge Mary Pat
Thynge to reside with his sister, Michelle Wallace, at altimore, MD, as
a condition of his pre-trial release.
2. Mr. Wallace now wishes to change his residence and reside at_
¢ Baltimore, MD,-
3. Mr. Wallace’s District of Delaware U.S. Pre-trial Services Officer, Carol Sain, has
no objection to Mr. Wallace’s request for a change of residence. Mr. Wallace is currently being
supervised by the Baltimore Pre-trial Services Office. Defense counsel has been informed by USPO
Carol Sain that Mr. Wallace’s Baltimore supervising U.S. Probation Officer, Susanna Merchant, also

Case 1:07-cr—OOO26-SLR Document 13 Filed O3/30/2007 Page 2 of 4
Case 1:07-cr-00026-SLR Document 12 Filed 03f30f2007 Page 2 of 3
has no objection to Mr. Wallace’s request for a change ofresidence to the address stated in this motion.
4. Shannon Thee Hanson, the attorney handling this case for the govermnent, is out of
the office until April 2, 2007, and defense counsel was unable to speak with her to ascertain the
govemment’s position on this motion.
WHEREFORE, Mr. Wallace respectfully requests that the Court sign the attached Order
for Modification of`Residence.
Respectfully Submitted,
fsf
Eleni Kousoulis, Esquire
Assistant Federal Public Defender
704 King Street, Suite 110
Wilmington, Delaware 19801
(302) 573-6010
ecf` dega7msn.com
Attorney for Defendant Earl Wallace
DATED: March 30, 2007
2

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Case 1:07-cr-00025-SLR Document 12 Filed 03/30f2007 Page 3 013
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Piamia; Z
v. Criminal Action No. 07-26-SLR
EARL WALLACE,
Defendant.
CERTIFICATE OF SERVICE
The undersigned attorney for Defendant Earl Wallce hereby certifies that on March 30, 2007,
two (2) copies ofthe attached Motion for Modification were placed in a box in the United States
District Court of the District of Delaware addressed to the following person(s):
CAROL SAIN, USPO
U.S. Probation and Pre-trial Services
Suite 400, 824 Market Street
Wilmington, DE 19801
fs!
ELENI KOUSOULIS, ESQUIRE
Assistant Federal Public Defender
704 King Street, Suite 1 10
Wilmington, Delaware 19801
Attorney for Defendant Earl Wallace

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Case 1:07-cr—O0026—SLR Document 12-2 Filed 03!30f2007 Page 1 of1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
Piamurr; Q
v. Criminal Action No. 07·26-SLR
EARL WALLACE,
Defendant.
ORDER
In response to Mr. Wal|ace’s Motion for Modification of` Residence, it is HEREBY
ORDERED on this day of , 2007, that Defendant Earl
Wallace be permitted to change his residence to aItimore, MD,
The Honorable Sue L. Robinson
United States District Judge