Free Motion for Miscellaneous Relief - District Court of California - California

Case 3:08-cr-00298-SI

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Filed 06/04/2008

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BARRY J. PORTMAN Federal Public Defender GEOFFREY A. HANSEN Chief Assistant Federal Public Defender 19th Floor Federal Building ­ Box 36106 450 Golden Gate Avenue San Francisco, CA 94102 Telephone: (415) 436-7700 Counsel for Defendant LINTZ

6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 On May 16, 2008, this Court released the defendant on a bond secured by the signature of his mother, with the condition that Mr. Lintz be required to reside at Cornell Corrections on a 24 hour basis except for trips to Court. So far, Mr. Lintz has followed all of the rules of Cornell and has done everything asked of him at the halfway house. As a result, the defendant files this motion to ask for two modifications. First, he asks that the Court modify his release conditions to allow him to come to counsel's office for legal visits. This will allow Mr. Lintz to discuss the case with counsel and review the relevant discovery. Second, Mr. Lintz's mother has called counsel and asked that he be allowed to go to her house for approximately one hour to sign some legal papers which need his signature, and which must be signed in the presence of a third party at the apartment complex 1 UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) ) vs. ) ) JAMES LINTZ, ) ) Defendant. _____________________________________ ) No. CR-08 - 298 SI MOTION TO AMEND CONDITIONS OF BAIL Before: Magistrate Judge Edward Chen IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

BAIL MOTION

Case 3:08-cr-00298-SI

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where she resides. Mr. Lintz understands that if permission is granted for this trip to his mother's residence, the trip must be approved by Pretrial Services. This court might recall that Ms. Lintz asked to be notified about any change in his conditions of his release; obviously, because she has requested this visit, counsel has discussed this matter with her and she has no objection. A proposed order is attached.

Dated: June 4, 2008 Respectfully submitted, BARRY J. PORTMAN Federal Public Defender /s/

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 2 GEOFFREY A. HANSEN Chief Assistant Federal Public Defender

BAIL MOTION

Case 3:08-cr-00298-SI

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 1 Dated: _____________________________ Edward M. Chen United States Magistrate Judge The defendant's conditions of release are modified as follows: subject to the approval of Pretrial Services, the defendant may: (1) leave Cornell Corrections to meet with counsel at his office; and (2) the defendant may travel to his mother's residence to sign legal papers on one occasion. UNITED STATES OF AMERICA, ) ) Plaintiff, ) ) vs. ) ) JAMES LINTZ, ) ) ) Defendant. _____________________________________ ) No. CR-08 - 298 SI ORDER MODIFYING CONDITIONS OF BAIL IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA