Court filing

Motion — United States v. David Butziger (Dkt. 15, D.R.I. No. 1:20-cr-00072)

Filed May 28, 2020 in Butziger; one of 33 filings from this case.

Record facts

Court	U.S. District Court for the District of Rhode Island
Filed	2020-05-28

U.S. District Court for the District of Rhode Island · No. 1:20-cr-00072-MSM-LDA · Doc. 15 · 2020-05-28 · 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 into bordering
states, 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 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.
4. This business also provides drug and alcohol testing for marine professionals. Often he
receives emergency requests for out of state testing. Because of his restrictions, he is
unable to confirm and attend these appointments until he receives permission for the
Court. This also results in numerous, last minute motions being filed by the defense to
address new work orders.
5. Therefore, Mr. Butziger seeks permission from to Court to be allowed travel to states in
Case 1:20-cr-00072-MSM-LDA Document 15 Filed 05/28/20 Page 1 of 3 PageID #: 50

the surrounding area, to include Massachusetts, Connecticut, New York, New Hampshire
and Maine, for employment purposes, providing he provides advance notice to his
attorney and U.S. Probation before leaving, and confirms his return.
6. Mr. Butziger has petitioned this Court on two separate occasions requesting a bail
modification to allow him to travel to Albany, NY and Massachusetts, for employment
purposes, which the Court allowed.
7. Mr. Butziger continues to be in full compliance with all the terms 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 other states for employment purposes.
Respectfully submitted this 28th 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

Case 1:20-cr-00072-MSM-LDA Document 15 Filed 05/28/20 Page 2 of 3 PageID #: 51

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 28, 2020.