Agreed Motion to Modify Conditions of Release — USA v. Vazquez (Dkt. 8, S.D. Fla. No. 1:21-mj-02512)

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UNITED STATES DISTRICT COURT 
 SOUTHERN DISTRICT OF FLORIDA 
 
CASE NO:  21-mj-02512-CMM 
 
 
 
 
 
UNITED STATES OF AMERICA, 
 
 
 
 
Plaintiff, 
vs. 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
CARLOS VAZQUES,  
 
 
 
Defendant. 
____________________________________/ 
 
AGREED MOTION TO MODIFY COURT ORDERED CONDITION OF RELEASE 
 
 
The Defendant, Carlos Vazquez, by and through his undersigned counsel, respectfully 
requests that the Honorable Court enter an Order allowing the Defendant to sign and return his 
appearance bond papers within 24 hours of being released from custody.  As grounds for this 
request, the Defendant states the following:   
 
1.  At the Bond Hearing on March 29, 2021, the Honorable Court ordered the following 
appearance bond conditions: 
• A $500,000.00 personal surety bond to be co-signed by Ms. Annabel Lee.  Ms. Lee 
has already signed the surety section of the appearance bond. 
• A $50,000.00 10 percent bond with a Nebbia satisfaction requirement. 
• Surrender of all passports and travel documents. 
• Random urine testing by Pretrial Services and follow-up treatment if deemed 
necessary. 
• Participate in a mental health assessment and treatment.   

 
2 
• No contact with Government witnesses. 
• No possession of firearms, ammunition or any other dangerous devices. 
• The Defendant is prohibited from entering his personal residence at                        
5249 NW 7th Street, Apartment # 408, Miami, Florida 33126 until the Case Agent 
or other arrangements are made to retrieve the firearm located at the residence. 
• The Defendant has to reside with Ms. Annabel Lee at 15479 SW 35 Terrace,         
Miami, Florida 33185 upon his release from custody. 
3.  AUSA Hayden O’Byrne has no objection to the Honorable Court modifying the 
condition of bond by allowing the Defendant to sign and return the appearance bond papers within 
24 hours of his release from custody.  
WHEREFORE, Mr. Vazquez respectfully requests that the Honorable Court grant the relief 
requested in this Agreed Motion to Modify Court Ordered Condition of Release. 
CERTIFICATE OF SERVICE 
I HEREBY CERTIFY that on March 31, 2021, I electronically filed the foregoing document with 
the Clerk of the Court using CM/ECF.  I also certify that the foregoing document is being served 
this day on all counsel of record or pro se parties, either via transmission of Notices of Electronic 
Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who 
are not authorized to receive electronically Notices of Electronic Filing.  
 
Respectfully submitted, 
 
JACOB A. COHEN, ESQ. 
Law Offices of Jacob A. Cohen, PLLC 
 
 
 
 
 
 
750 South Dixie Highway 
 
 
 
 
 
 
Boca Raton, FL 33432 
 
 
 
 
 
 
Telephone 561-715-7866 
 
 
 
 
 
 
E-mail – jacob@jacobcohenlaw.com  
By: /s/ Jacob A. Cohen, Esq. 
 
 
 
 
 
 
       Jacob A. Cohen, Esq. 
                                                                               Fla. Bar No. 0162530

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