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

v_ e ,_ Case 1 :08-cr-00061-SLR Document 20 Filed 07/22/2008 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AIVIERICA, :
v. Criminal Action N0. 08-00061-UNA
LESLIE VSOTO,
Defendant.
MOTION FOR MODIFICATION
OF A CONDITION OF PRETRIAL RELEASE
Defendant Leslie Soto, by her undersigned attorney, hereby requests that the Court issue an
order modifying the condition of her pretrial release requiring that she be held on home confinement. In
support of this request, the Defendant sets forth the following:
1. Ms. Soto has been on pretrial release on home confinement since March 26, 2006.
2. Ms. Soto is being supervised by probation officer Craig Carpenter. Ms. Soto has _
complied with all of Officer Carpenter’s recommendations, has obtained employment, has been
attending sessions at a mental health clinic, and has generally done everything he has requested of her.
Officer Carpenter advises cornrsel that this is in fact the case.
3. Ms. Soto now has an opportunity to obtain an apartment, independent of her current
housing, where she would reside with her son with whom she has been in constant contact.
4. Given Officer Carpenter’s agreement that this change in her status would not be
inappropriate, counsel contacted Joseph Grubb, Esquire of the U.S. Attorney’s office and he does not
i oppose the change in condition.

M _ Case 1 :08—cr—00061-SLR Document 20 Filed 07/22/2008 Page 2 of 4
WHEREFORE, Defendant Leslie Soto requests that the Coiut grant her request for a
nioditication ofthe home confmeinent condition of pretrial release.
JOSEPH W. BENSON, P.A.
/s/ Joseph W. Benson
Joseph W. Benson, Esquire
Bar lD# 196
/s/ Andrew G. Ahern HI
Andrew G. Ahem IH, Esquire
Bar lD# 2083
1701 North Market Street
P.O. Box 248
Wihnington, DE 19899
(302)656—88l1
Attorney for Defendant Leslie Soto
DATED: July 22, 2008

{ p Case 1 :08-cr-00061-SLR Document 20 Filed 07/22/2008 Page 3 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
UNITED STATES OF AMERICA, :
v. : Criminal Action No. 08-00061-UNA
LESLIE SOTO, :
Defendant. :
ORDER
This day of 2008, the foregoing Motion for Modification of a
Condition of Pretrial Release having been heard and considered,
IT IS ORDERED that the motion is GRANTED and Defendant shall no longer be held under
home confinement while on pretrial release. All other conditions and requirements of pretrial release
shall remain in full effect.
The Honorable Sue L. Robinson

p _ T Case 1 :08-cr-00061-SLR Document 20 Filed 07/22/2008 Page 4 of 4
CERTIFICATE OF SERVICE
I, the undersigned, Joseph W. Benson, Esquire, do hereby certify that I caused to be delivered
by first class mail 2 copies of the foregoing Motion for Modihcation of a Condition of Pretiial Release
as follows:
Joseph R. Gnibb, Esquire
Special Assistant United States Attorney
P.O. Box 2046
Wilmington, DE l9899—2046
JOSEPH W. BENSON, P.A.
/s/ Joseph W. Benson
Joseph W. Benson, Esquire
Bar 1D# 196
/s/ Andrew G. Aheni HI, Esquire
Andrew_G. Ahern
Bar lD# 2083
1701 North Market Street
P.O. Box 248
Wihnington, DE 19899
(302)656—88l1
. Attorney for Defendant
Leslie Soto
DATED: July 22, 2008

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