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

Case 3:02-cr-00056-AHN

Document 34

Filed 12/13/2004

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT UNITED STATES OF AMERICA vs. AMIR OMEROVIC : : : : : :

CRIM. NO. 3:02CR56(AHN) DECEMBER 10, 2004

MOTION TO MODIFY THE CONDITIONS OF RELEASE The defendant, Amir Omerovic, through counsel, Paul F. Thomas, respectfully requests that this Court grant permission for him to travel to Bosnia from December 25, 2004 through January 26, 2005. In support of this motion, counsel states: (1) Mr. Omerovic was arrested and presented on November 1, 2001 and charged with mailing a threatening communication and threatening the people and property of the United States with a biological agent in violation of 18 U.S.C. §§ 876 and 2332a(a)(3). (2) Mr. Omerovic waived indictment and pled guilty to an information that charged him with mailing a threatening communications. (3) On July 29, 2003, the Court sentenced Mr. Omerovic to imprisonment for ten months and supervised release for three years. (4) As a condition of supervised release Mr. Omerovic is not permitted to travel out of this country without permission from the Court. Mr. Omerovic came to this country as a refugee from Bosnia, where he was seriously wounded in the civil war and where his parents still reside. Mr. Omerovic receives military disability payments from the Bosnian government, but he is required to undergo a physical examination and eligibility review to continue receiving those benefits. An examination and review has been scheduled for January 10, 2005. Mr. Omerovic would also use the time in Bosnia to visit with his parents and to explore business and educational opportunities that he might choose to pursue in Bosnia after he completes his term of supervised release. (5) If permitted to travel to Bosnia he would stay at: Trg Zaunobih-a 32/3, 71,000 Sarajero, Bosnia/Herzajivinia Tel. (387) 33 453-617

Case 3:02-cr-00056-AHN

Document 34

Filed 12/13/2004

Page 2 of 2

(6) Assistant United States Attorney Brian Spears and U.S. Probation Officer Patrick Norton have no objection to this motion.

Respectfully submitted, THE DEFENDANT, AMIR OMEROVIC THOMAS G. DENNIS FEDERAL DEFENDER

Dated: DECEMBER 10, 2004 Paul F. Thomas Asst. Federal Defender 2 Whitney Ave., Suite 300 New Haven, CT 06510 Bar No. ct01764 (203) 498-4200

CERTIFICATION I HEREBY CERTIFY that a copy of the foregoing MOTION TO MODIFY THE CONDITIONS OF RELEASE has been mailed to Brian Spears, Assistant United States Attorney, and to Patrick Norton, United States Probation Officer, 157 Church Street, New Haven, CT 06510, on this 10th day of December 2004.

__________________________ Paul F. Thomas

-2-