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

Case 3:02-cr-00341-EBB

Document 830

Filed 04/21/2008

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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 : APRIL 18, 2008

DEFENDANT DAVID BROWN'S MOTION FOR MODIFICATION OF CONDITIONS OF RELEASE The defendant David Brown hereby moves this Court for an order modifying the conditions of his release as follows: 1. Allowing him to participate in his family's business as his father has suffered a recent

heart attack and is unable to conduct the business by himself. 2. As a result of participating in his father's business, Mr. Brown will sometimes

have to work throughout the night cleaning buildings and performing other services. 3. It is expected that he will know when he has to work throughout the night

approximately one week before performing those services and ask that the Court allow him to do so if he notifies the Probation Office at least 72 hours before performing such work and receives the consent of the Probation Office to perform the specific services that will be performed during the evening hours. 4. The defendant will consent to any other reasonable conditions imposed by the Court

Case 3:02-cr-00341-EBB

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which serve to insure that the Probation Office will be able to satisfactorily monitor him during those working hours. 5. The undersigned has spoken to Meghan Nagy of the United States Probation Office

and she has suggested the contents of this motion since she and the defendant have discussed this issue. WHEREFORE, the defendant requests that the conditions of release be modified accordingly and that the Court schedule a hearing to address these issues and any other concerns that the Court might have before modifying Mr. Brown's conditions. 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

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CERTIFICATION This will certify that a copy of the foregoing Motion for Modification of Conditions of Release mailed postage pre-paid to The Honorable Ellen B. Burns, 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; 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 065071277; and Michael S. Hillis, Esq., Dombroski, Knapsack & Hillis, LLC, 129 Whitney Avenue, New Haven, CT 06510-1232 on this 18th day of April, 2008.

_________________________________________ ROBERT C. MIRTO

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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 : APRIL 18, 2008

Please take notice that Defendant David Brown has manually filed the following document: Motion for Modification of Conditions of Release This document has not been filed electronically because: [ [ ] ] the document cannot be converted to an electronic format the electronic file size of the document exceeds 1.5 megabytes the document is filed under seal pursuant to Local Rule of Civil Procedure 5(d) or Local Rule of Criminal Procedure 57(b) [ X ] Plaintiff/Defendant is excused from filing this document by Court order. The document has been manually served on all parties. Respectfully submitted, _________________________________________ ROBERT C. MIRTO, #ct 00188 140 Captain Thomas Boulevard P.O. Box 428

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West Haven, CT 06516 Telephone No.: (203)932-2225 Fax no.: (203)-934-4834 E-mail: [email protected]

Case 3:02-cr-00341-EBB

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