Free Motion to Amend/Correct - District Court of Delaware - Delaware

Case 1:06-cr-00085-SLR

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GLENN A. ZEITZ, ESQUIRE Attorney I.D.: 15930 38 Haddon Avenue Haddonfield, New Jersey 08033 (856) 795-6660 Attorney for Defendant Steven Humes

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ____________________________________________________________________ UNITED STATES OF AMERICA : : : vs. : Criminal No.: 06-85 (SLR) : : STEVEN HUMES : : ____________________________________________________________________

NOTICE OF MOTION TO AMEND CONDITION OF PRE-TRIAL RELEASE

TO:

Edmund Falgowski, A.U.S.A. United States Attorney's Office District of Delaware P.O. Box 2046 Wilmington, Delaware 19809

PLEASE TAKE NOTICE that on September 26, 2006, at 8:30 A.M. or as soon thereafter as counsel may be heard, the defendant, STEVEN HUMES, by and through his attorney, GLENN A. ZEITZ, ESQUIRE will move before the Honorable Mary Pat Thynge, United States Magistrate Judge, at the United States Courthouse, Wilmington, Delaware, for the following relief: Page -1-

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For an Order amending defendant's conditions of pre-trial release to permit defendant to be treated by Grant R. Hasty at least one time per week and by Dr. Elliot Atkins at least one time per month. All other conditions to remain the same Defendant Steven Humes will rely upon oral argument together with the attached Statement In Support of Motion To Amend Condition of Pre-trial Release attached herewith. RESPECTFULLY SUBMITTED:

Dated: September 20, 2006

/s/ Glenn A. Zeitz GLENN A. ZEITZ, ESQUIRE Attorney for Defendant Steven Humes

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GLENN A. ZEITZ, ESQUIRE Attorney I.D.: 15930 38 Haddon Avenue Haddonfield, New Jersey 08033 (856) 795-6660 Attorney for Defendant Steven Humes

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ____________________________________________________________________ UNITED STATES OF AMERICA : : : vs. : Criminal No.: 06-85 (SLR) : : STEVEN HUMES : : ____________________________________________________________________

STATEMENT IN SUPPORT OF DEFENDANT'S MOTION TO AMEND CONDITIONS OF PRE-TRIAL RELEASE

GLENN A. ZEITZ, ESQUIRE, hereby states as follows: 1. 2. I represent defendant Steven Humes in the above-captioned matter. On August 16, 2006, this Court issued an Order requiring, inter alia, that Mr.

Humes "be seen by Dr. [Elliot] Atkins no less than once a week". Dr. Atkins fee for a onehour visit is $300.00. 3. For financial reasons, Mr. Humes and his family would like him to receive the

majority of his treatment from Grant R. Hasty who is a clinical social worker at Red Lion

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Christian Counseling Center; a copy of Mr. Hasty's resume is attached hereto as Exhibit A. Mr. Hasty's fee for a one-hour visit is $30.00. 4. Both Dr. Atkins and Mr. Hasty will share information and participate

concerning Mr. Humes' mental health condition. Dr. Atkins will see Mr. Humes at least one time each month and will prepare a status report based on his personal observations and those of Mr. Hasty. 5. Mr. Humes and his family have limited financial resources which must be

allocated for defense investigation and preparation. The family and Mr. Humes have retained private counsel, an investigator, and may need to consult with and retain other experts in this matter. 6. Mr. Humes respectfully requests that he be permitted to treat with Mr. Hasty

at least once a week and with Dr. Atkins at least once a month.

RESPECTFULLY SUBMITTED:

Dated: September 20, 2006

/s/ Glenn A. Zeitz GLENN A. ZEITZ, ESQUIRE Attorney for Defendant Steven Humes

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GLENN A. ZEITZ, ESQUIRE Attorney I.D.: 15930 38 Haddon Avenue Haddonfield, New Jersey 08033 (856) 795-6660 Attorney for Defendant Steven Humes

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE ____________________________________________________________________ UNITED STATES OF AMERICA : : : vs. : Criminal No.: 06-85 (SLR) : : STEVEN HUMES : : ____________________________________________________________________ ORDER AND NOW, upon consideration of defendant's motion and statement in support of amending his conditions of pre-trial release; the Government's memorandum of law in opposition to same; and the arguments of counsel; IT IS ORDERED, this motion is granted. BY: day of , 2006, that defendant's

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CERTIFICATE OF SERVICE I hereby certify that on this date a true and correct copy of Defendant's Notice of Motion to Amend Bail Conditions has been delivered electronically to the following:

Edmund Falgowski, A.U.S.A. United States Attorney's Office District of Delaware P.O. Box 2046 Wilmington, Delaware 19809

Dated: September 20, 2006

/s/ Glenn A. Zeitz GLENN A. ZEITZ, ESQUIRE Attorney for Defendant Steven Humes