Free Motion to Modify Conditions of Release - District Court of Connecticut - Connecticut

Case 3:02-cr-00341-EBB

Document 834

Filed 05/19/2008

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA VS. SHORELINE MOTORS, ET AL : CRIMINAL NO.: 3:02CR00341-EBB : JUDGE ELLEN BREE BURNS : MAY 19, 2008

DEFENDANT DAVID BROWN'S MOTION FOR MODIFICATION OF TERMS OF RELEASE The defendant David Brown hereby moves this Court for an order permitting him to attend his daughter's graduation in Memphis, Tennessee on May 21, 2008. The defendant has previously been released by this Court with conditions that he not travel from the State of Connecticut. However, his daughter is graduating from high school and is in the process of entering college. She resides in Memphis and the defendant wishes to attend her graduation. Respectfully Submitted, THE DEFENDANT, DAVID BROWN

BY:______________________________________ ROBERT C. MIRTO Mirto, Ketaineck & DiCrosta, P.C. 140 Captain Thomas Blvd., P.O. Box 428 West Haven, CT 06516 Tph. #(203)932-2225 ct 00188

Case 3:02-cr-00341-EBB

Document 834

Filed 05/19/2008

Page 2 of 2

CERTIFICATION This will certify that a copy of the foregoing Motion for Modification of Terms of Release was hand-delivered to the Hon. Joan G. Margolis, Magistrate Judge, U.S. District Court, 141 Church Street, New Haven, CT 06510; Michael S. McGarry, Esq., Assistant U.S. Attorney, Office of the U.S. Attorney, 157 Church Street, 23rd Floor, New Haven, CT 06510; Meghan Nagy, U.S. Probation Officer, U.S. Probation Department, 915 Lafayette Boulevard, Room 200, Bridgeport, CT 06604; and mailed to Jonathan J. Einhorn, Esq., 412 Orange Street, New Haven, CT 06511; Kurt F. Zimmermann, Esq., Silverstein & Osach, P.C., 234 Church Street, #903, P.O. Box 1727, New Haven, CT 06507-1277; and Michael S. Hillis, Esq., Dombroski, Knapsack & Hillis, LLC, 129 Whitney Avenue, New Haven, CT 06510-1232 on this 19th day of May, 2008.

_________________________________________ ROBERT C. MIRTO