Free Motion for Reconsideration - District Court of Delaware - Delaware

· Case 1:06—cr—00085-SLR Document 17 Filed 08/10/2006 Page1 of 3
GLENN A. ZEITZ, ESQUIRE
Attorney I.D.; 15930 p
38 Haddon Avenue
Haddonfield, New Jersey 08033 Q ,1
(856) 795-6660 ·-QQ . V
Attorney for Defendant Steven Humes C1 Ii __.- LQ _-A9 .
IN THE UNITED STATES DISTRICT COLIRT Iii; ;_
FOR THE DISTRICT OF DELAWARE Y`
UNITED STATES OF AMERICA 1
vs. Criminal No.; 06-85
STEVEN HUMES
NO'I'ICE OF MOTION TO AMEND DEFENDANT’S DETENTION STATUS
BASED ON A MATERIAL CHANGE OF CIRCUMSTANCES
TO: Douglass McCann, A.U.S.A.
United States Attorney’s Office —
District of Delaware
P.O. Box 2046
Wilmington, Delaware 19809
PLEASE TAKE NOTICE that on a date to be set by the Court, at 10:00 AM. in the
forenoon, or as soon thereafter as counsel may be heard, the defendant, STEVEN
HUIVIES, 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-

_ Case 1:06—cr—00085-SLR Document 17 Filed 08/10/2006 Page 2 of 3 ·
1. For an Order sealing the record.
2. For an Order amending defendant’s detention status to permit bail with any
conditions the Court deems appropriate.
Defendant, STEVEN l—lUl\/IES, will rely upon oral argument together with the
attached Memorandum of Law submitted herewith.
RESPEOTFULLY WTTED:
l /I/I l ///4 _ ;//,. · '
Dated: August 10, 2006 » I __ ;' .
GLENN A. ZEITZ, SOUIRE
Attorney for Defendant Steven Humes
Page -2-

Case 1:06—cr—00085-SLR Document 17 Filed 08/10/2006 Page 3 of 3 .
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
STEVEN HUI\/IES
ORDER
AND NOW, upon consideration of defendant’s motion and memorandum of law in
support of amending his detention status based on a material change of circumstances;
the Government’s memorandum of law in opposition to same; and the arguments of
counsek
IT IS ORDERED, this day of ,2006, that defendants
motion is granted.
IT IS FURTHER ORDERED that the record shall be sealed.
BY: