Unopposed Motion to Modify Conditions of Release — USA v. Smith (Dkt. 27, S.D. Fla.)

Record facts

U.S. District Court for the Southern District of Florida · No. 1:21-cr-20001-MGC · Doc. 27 · 2021-05-27 · Docket on CourtListener

Full text

1 
 
UNITED STATES DISTRICT COURT 
SOUTHERN DISTRICT OF FLORIDA 
MIAMI DIVISION 
 
CASE NO.:   21-CR-20001-MGC 
 
 
UNITED STATES OF AMERICA,  
 
 
  
v. 
 
DIAMOND BLUE SMITH, 
Defendant, 
_________________________________/ 
 
DEFENDANT DIAMOND BLUE SMITH’S UNOPPOSED MOTION TO MODIFY 
CONDITION OF PRETRIAL RELEASE 
 
DEFENDANT DIAMOND BLUE SMITH respectfully requests the Court to modify his 
conditions of pretrial release by allowing him to reside with his girlfriend and their newborn son.  
The grounds for this motion are as follows:  
1. On October 8, 2020, the Court granted pretrial release for Diamond Blue Smith on $250,000 
PSB with standard conditions. 
2. Mr. Smith’s girlfriend Caroline Torres recently gave birth to their son.  Mr. Smith wishes to 
move into Ms. Torres’ home located at 18031 NW 87th Court, Hialeah, Florida, 33018 and 
live with her and their child.    
3. Probation officer Nelson Valenzuela confirmed that Mr. Smith is compliant with all 
conditions of release, and he does not oppose this motion. 
 
WHEREFORE, Mr. Smith moves the Court to modify his conditions of pretrial release to  
allow him to reside at 18031 NW 87th Court. 
 
Case 1:21-cr-20001-MGC   Document 27   Entered on FLSD Docket 05/27/2021   Page 1 of 2

2 
 
LOCAL RULE 88.9 CERTIFICATION 
 
I CERTIFY that I discussed this motion with Assistant U.S. Attorney Aimee Jimenez 
who advised that she does not oppose this relief.   
 
 
 
 
 
 
 
 
Submitted by: 
  
/s/ Adriana Collado-Hudak 
 
 
 
 
 
 
 
Fla. Bar No. 830461 
 
 
 
 
 
 
 
Greenspoon Marder LLP  
 
 600 Brickell Avenue  
 
 36th Floor 
 
 
 
 Miami, FL 33131 
 
 
 
305-789-2713  
 
 
 
 
adriana.collado-hudak@gmlaw.com 
 
 
CERTIFICATE OF SERVICE 
I CERTIFY that I filed a copy of the foregoing via CM/ECF on May 27, 2021, and it was 
thereby served on all parties of record. 
/s/ Adriana Collado-Hudak 
 
 
 
 
 
 
 
Fla. Bar No. 830461 
Case 1:21-cr-20001-MGC   Document 27   Entered on FLSD Docket 05/27/2021   Page 2 of 2

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