Court filing

Motion — United States v. David Butziger (Dkt. 10, D.R.I. No. 1:20-cr-00072)

Filed May 14, 2020 in Butziger; one of 33 filings from this case.

Record facts

Court	U.S. District Court for the District of Rhode Island
Filed	2020-05-14

U.S. District Court for the District of Rhode Island · No. 1:20-cr-00072-MSM-LDA · Doc. 10 · 2020-05-14 · Docket on CourtListener

Full text

UNITED STATES DISTRICT COURT
DISTRICT OF RHODE ISLAND

UNITED STATES OF AMERICA
:

:
V.

Case No.: 1:20-MJ-33-LDA

:
DAVID BUTZIGER

DEFENDANT’S MOTION TO MODIFY CONDITIONS

Now comes Defendant, David Butziger, by and through counsel, and hereby moves this
Honorable Court to modify the conditions of his release to allow him to travel to the District of
Massachusetts for the purpose of employment. As grounds for this request, Mr. Butziger avers
the following:
1. Mr. Butziger is charged with Conspiracy to Make False Statement to Influence the SBA,
in violation of 18 U.S.C. § 371; Conspiracy to Commit Bank Fraud, in violation of 18
U.S.C. § 1349; and Bank Fraud, in violation of 18 U.S.C. § 1344 (2).
2. He initially appeared, telephonically, before the Court on May 5, 2020 and was released
on $10,000.00 unsecured bond with conditions that include restricting his travel to the
District of Rhode Island.
3. Mr. Butziger seeks to modify this condition to allow him to travel into Massachusetts.
4. Mr. Butziger is the owner and operator of Dock Wireless, located at 44 Bowen Briggs
Avenue, Warwick, RI 02886. This company specializes in telecommunication services
and full-service wireless internet networks for boats and marinas.
5. This business also provides drug and alcohol testing for marine professionals.
6. Mr. Butziger seeks permission from to Court to travel to Massachusetts where some of
his equipment suppliers are located. For example, he has a business relationship with
Micro Center, located at 730 Memorial Drive, Cambridge, MA 02139 from which he
obtains commercial grade equipment for his business that is unavailable locally. Mr.
Case 1:20-cr-00072-MSM-LDA Document 10 Filed 05/14/20 Page 1 of 2 PageID #: 36

Butziger also has a customer base in Massachsuetts to whom he sells equipment and
provides services.
7. Mr. Butziger is in full compliance with all the terms and conditions of his release.
8. The government has no objection to this modification request.
9. Based upon the foregoing, Mr. Butziger asks to this motion be granted to modify his
conditions of release to allow travel into Massachusetts for employment purposes.
Respectfully submitted this 14th day of May 2020.
Respectfully submitted
DAVID BUTZIGER
By his Counsel,

/s/ John L. Calcagni III, Esq.

John L. Calcagni III (# 6809)

One Custom House Street, Suite 300

Providence, RI 02903

Phone: (401) 351.5100

Fax: (401) 351.5101

Email: jc@calcagnilaw.com

CERTIFICATION

I hereby certify that this document, filed through the ECF system, will be sent
electronically to the registered Participants as identified on the Notice of Electronic Filing (NEF)
and paper copies will be sent to those indicated as nonregistered participants on May 14, 2020.