Free Motion to Travel - District Court of Connecticut - Connecticut

Case 3:03-cr-00249-RNC Document 78 Filed 1 1/10/2004 Page 1 of 3 A
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
UNITED STATES OF AMERICA : CRIM. NO. 3:03CR249(RNC)
V. :
CHRISTINA DIXON : NOVEMBER 5, 2004 j
MOTION FOR MODIFICATION OF CONDITIONS OF RELEASE
The undersigned respectfully requests that this Court modify the
conditions of bond placed upon the defendant, Christina Dixon, as follows:
the defendant requests that the Court allow her to travel by plane to the State
of New Mexico before her next scheduled Court appemance of January 7, ;
2005.
The defendant last appeared before the Court on November 3, 2004, at
which time the undersigned explained to the Court that the defendant’s father
offered an automobile to her located in New Mexico, and that the defendant y
would need to travel to New Mexico to claim the automobile. The defendant
ORAL ARGUMENT NOT REQUESTED .
Rome McGuigan, P.C. · Attorneys at Law
One State Street • Hartford, Connecticut 06103-3101 • (860} 549-1000 · Fax(860) 724-3921 • Juris No. 27726 _

Case 3:03-cr-00249-RNC Document 78 Filed 1 1/10/2004 Page 2 of 3
. the automobile will help facilitate the types of changes the Court would like to L
see from the defendant before her appearance on January 7, 2005. The travel
to New Mexico will be monitored by United State’s Probation Officer Katya Q3;
Lopez. It should be noted that Ms. Lopez concurs with this Motion.
WHEREFORE, the defendant requests the Court to modify the
conditions of release and allow the Defendant to travel to New Mexico.
DEFENDANT _ l
c s r A D oi~1
By " E
A. an Mc uigan, Esxj _.
Rome McGuigan, P.C. ‘
One State Street A
Hartford, CT 06103 A
(860) 549-1000
Her Attorneys
2
Rome McGuigan., P.C. · Attomeys atLczw n
One State Street · Hartford, Connecticut 06103-3101 • (860)549-1000 · Fax (860) 724-3921 • Juris No. 27726

Case 3:03-cr-00249-RNC Document 78 Filed 11/10/2004 Page 3 of 3 I
CERTIFICATE OF SERVICE Q
This is to certify that on the Sth day of November 2004, a copy ofthe
foregoing was mailed, postage prepaid, via U.S. mail, to: g
Jonathan Biran, Esq.
Assistant U.S. Attorney
157 Church Str , 23rd Floor f
New Z, 0651 O -·‘‘ .-si ‘ " `
. Rya ‘·' oGuig2m ` in .
11911-1/382127
3
Rome M'CGtlfg¤J1, P.C. • Attorneys r1tLcu.u
One State Street • Hartford. Connecticut 06103-3101 • [860) 549-1000 · Fax[860)724—3921 - Juris No. 27726 _